G.R. No. 195097 ; August 13, 2012
Republic of the Philippines, Petitioner, vs. Marlon Medida, Respondent.

FACTS

Respondent Marlon Medida filed a petition for registration of title over two parcels of land in Boljoon, Cebu. He claimed ownership through purchase in 1997, asserting that he and his predecessors-in-interest had possessed the lots openly and continuously. During trial, Medida presented, among other evidence, Advance Survey Plans for the lots which contained notations indicating the lands were within areas classified as alienable and disposable in 1980 and 1987, respectively. The Regional Trial Court granted the petition. The Republic appealed, arguing that Medida failed to prove the requisite possession since the period should only be reckoned from the dates the lands were declared alienable. The Court of Appeals affirmed the RTC decision, ruling that jurisprudence only requires the land to be alienable at the time of the application filing, not that possession prior to such classification be excluded.

ISSUE

Whether the respondent successfully proved that the subject parcels of land are alienable and disposable lands of the public domain, and whether he established open, continuous, exclusive, and notorious possession under a bona fide claim of ownership for the period required by law.

RULING

The Supreme Court granted the petition and denied the application for registration. The Court clarified that for original registration under Section 14(1) of Presidential Decree No. 1529, the applicant must prove that the land was already classified as alienable and disposable at the time the requisite period of possession commenced. Possession prior to such classification cannot be counted toward the statutory period. The Court found Medida’s evidence insufficient to establish the alienable status of the lands. The Advance Survey Plans containing mere surveyor’s notations, without being supported by a certified true copy of the original classification approved by the DENR Secretary, do not constitute conclusive proof. The certifications from the CENRO submitted later were also inadequate as they were not the required official declarations. Consequently, Medida failed to overcome the presumption that the lands remain part of the inalienable public domain. The Court emphasized the State’s paramount ownership under the Regalian doctrine and the applicant’s burden to present clear and convincing evidence of alienability, which was not met in this case.