G.R. No. 197389, October 12, 2020
Republic of the Philippines, Petitioner, vs. Manuel M. Caraig, Respondent.

FACTS

Respondent Manuel M. Caraig filed an application for original registration of title over Lot No. 5525-B, a 40,000-square meter parcel in Sto. Tomas, Batangas. He claimed ownership by purchase from Reynaldo S. Navarro in 1989 and asserted that Reynaldo and his predecessors-in-interest, beginning with Evaristo Navarro, had been in open, continuous, exclusive, and notorious possession and occupation of the land under a bona fide claim of ownership since prior to June 12, 1945. The Republic, through the OSG, opposed the application, contending the land was part of the inalienable public domain and that Caraig failed to prove the requisite possession.
During trial, Caraig presented multiple witnesses, including long-time residents of the barangay. They testified that they had known Evaristo Navarro as the owner since the 1940s, witnessing him and his workers cultivating the land with crops like coffee and banana. They further attested that possession passed to his son Reynaldo and then to Caraig, who built a house and planted crops on the property. Caraig also submitted certifications from the DENR-CENRO indicating the land was within an alienable and disposable zone.

ISSUE

Whether respondent Manuel M. Caraig has sufficiently established that the subject land is alienable and disposable and that he and his predecessors-in-interest have been in open, continuous, exclusive, and notorious possession and occupation under a bona fide claim of ownership since June 12, 1945, or earlier.

RULING

The Supreme Court denied the Republic’s petition and affirmed the grant of registration. The Court held that Caraig successfully proved the two indispensable requisites for judicial confirmation of imperfect title. First, he presented the requisite certifications from the DENR-CENRO. The March 21, 2003 CENRO certification positively stated the land was within the alienable and disposable zone per Project No. 30, Land Classification Map No. 582 certified on December 31, 1925. This constitutes substantial compliance with the required proof that the land was classified as alienable and disposable during the relevant period.
Second, the totality of the testimonial and documentary evidence established the required possession. The consistent testimonies of disinterested witnesses, who were long-time residents, provided credible and specific details of Evaristo Navarro’s acts of ownership and cultivation since before 1945. This possession was inherited by his son and later transferred to Caraig, whose own acts of occupation were also proven. The Court found no reason to disturb the concurrent factual findings of the MTC and the CA, which are accorded respect and finality. The evidence collectively demonstrated possession that was open, continuous, exclusive, and in the concept of an owner for the required statutory period.