G.R. No. 194617 , August 5, 2015
LA TONDEÑA, INC., PETITIONER, VS. REPUBLIC OF THE PHILIPPINES, RESPONDENT.

FACTS

La Tondeña, Inc. filed an application for registration of a 14,286-square-meter parcel of land in Bauang, La Union, alleging acquisition and possession even before the Second World War. It submitted various documents, including tax declarations dating back to 1948. During the proceedings, a DENR-CENRO Land Investigator submitted a Report dated May 31, 2005, stating that the land was declared alienable and disposable only on January 21, 1987. La Tondeña contended that this Report was not formally offered as evidence during the trial and it only learned of its existence during appeal. The Municipal Trial Court granted the application for registration. The Republic appealed, raising the DENR-CENRO Report. The Court of Appeals reversed the trial court’s decision and dismissed the application. La Tondeña filed this Petition, arguing the inadmissibility of the Report and, alternatively, that it had acquired a vested right over the land under the 1935 Constitution.

ISSUE

Whether the Court of Appeals erred in dismissing La Tondeña’s application for land registration.

RULING

No. The Supreme Court denied the Petition and affirmed the Court of Appeals’ Decision dismissing the application for registration.
The Court held that the applicant for judicial confirmation of imperfect title must prove: (a) the land forms part of the alienable and disposable agricultural land of the public domain, and (b) the applicant’s open, continuous, exclusive, and notorious possession and occupation of the land since June 12, 1945, or earlier. The burden of proof rests on the applicant, and the State cannot be put to the task of establishing its own title.
Regarding the DENR-CENRO Report, the Court ruled that while it was not formally offered, its contents were summarized in the trial court’s Decision, and La Tondeña did not object to this summary or move to strike it out. Therefore, it was properly considered. The Report categorically stated the land was certified alienable and disposable only on January 21, 1987. This fact was fatal to the application, as the requisite possession must be computed from a date when the land was already alienable. Since the land was classified as such only in 1987, possession before that date, even if since 1945, is inconsequential and cannot ripen into ownership.
The Court rejected La Tondeña’s argument that it acquired a vested right under the 1935 Constitution. The prohibition under the 1973 and 1987 Constitutions against private corporations acquiring alienable lands of the public domain applies to applications filed after their effectivity. However, this constitutional limitation is irrelevant if the applicant fails to prove the basic requisite that the land was already alienable and disposable during the period of its claimed possession. La Tondeña’s alternative argument on acquisitive prescription also failed, as the land remained part of the inalienable public domain until 1987, and prescription does not run against the State.
Finally, the Court found that La Tondeña failed to sufficiently prove the specific character and duration of its possession. The testimonies and tax declarations only established possession from 1948, not June 12, 1945, and did not convincingly demonstrate the nature of possession required by law.