G.R. No. 199310 ; February 19, 2014
Republic of the Philippines, Petitioner, vs. Remman Enterprises, Inc., represented by Ronnie P. Inocencio, Respondent.

FACTS

Remman Enterprises, Inc. applied for judicial confirmation of title over two parcels of land in Taguig. It claimed open, continuous, exclusive, and notorious possession by itself and its predecessors-in-interest since before June 12, 1945, originating from Veronica Jaime who cultivated the land since 1943. The respondent presented certifications from the DENR stating the lots were alienable and disposable, alongside deeds of sale, tax declarations, and survey plans. The Laguna Lake Development Authority (LLDA) opposed, asserting the lands were part of the Laguna Lake bed and thus inalienable, citing Section 41(11) of R.A. No. 4850 which designates lands at or below the reglementary elevation of 12.50 meters as public. An LLDA engineer testified that based on a 1966 topographic map and a 2002 verification, the lots’ elevations ranged from 11.33 to 11.77 meters.
The respondent presented a rebuttal witness, its own geodetic engineer, who conducted a separate survey and found the elevations to be between 12.60 and 15 meters, thus above the 12.50-meter threshold. The Regional Trial Court granted the application for registration, a decision affirmed by the Court of Appeals. The Republic, through the Office of the Solicitor General, elevated the case to the Supreme Court via a petition for review on certiorari.

ISSUE

Whether the respondent has sufficiently proven that the subject parcels of land are alienable and disposable lands of the public domain, considering the conflicting evidence on their elevation relative to Laguna Lake.

RULING

The Supreme Court denied the petition and affirmed the lower courts’ decisions. The legal logic centers on the burden of proof in land registration cases and the evaluation of conflicting evidence. An applicant for judicial confirmation of imperfect title must conclusively prove two elements: (1) that the land forms part of the alienable and disposable lands of the public domain, and (2) that the applicant and its predecessors-in-interest have been in open, continuous, exclusive, and notorious possession since June 12, 1945, or earlier. The Court found the respondent successfully discharged this burden.
Regarding alienability, the respondent presented positive certifications from the DENR. The LLDA’s contrary claim, based on elevation, was effectively rebutted by the respondent’s own topographic survey showing elevations above 12.50 meters. In weighing this conflicting technical evidence, the trial court’s factual findings favoring the respondent are accorded great weight and respect, especially as the CA affirmed them. The Supreme Court is not a trier of facts; absent a showing that the lower courts overlooked material facts, their assessment stands. Consequently, the respondent established the land’s alienable character. The Court also upheld the findings on possession, noting the unrebutted testimonial and documentary evidence tracing possession back to 1943. Thus, all requisites for registration under Section 14(1) of the Property Registration Decree were satisfied.