G.R. No. 200863 , October 14, 2020.
Republic of the Philippines, Petitioner, vs. Herederos de Ciriaco Chunaco Disteleria Incorporada, Respondent.

FACTS

Respondent Herederos de Ciriaco Chunaco Disteleria Incorporada (HCCDI), a domestic corporation, applied for land registration of Lot No. 3246 in Barangay Masarawag, Guinobatan, Albay, with the Municipal Trial Court (MTC). HCCDI claimed ownership through continuous, adverse, public, and uninterrupted possession since 1976 by virtue of a Deed of Assignment from the heirs of Ciriaco Chunaco, who allegedly possessed the lot since 1945 or earlier. The Republic of the Philippines, through the Office of the Solicitor General, opposed the application, arguing that neither HCCDI nor its predecessors-in-interest had possessed the land for the required period, that the land was not proven alienable and disposable, and that any claim based on a Spanish title was barred for failure to file within the period required by P.D. No. 892. The Land Management Office reported that the property was within an alienable and disposable zone classified on March 30, 1926, and was a coconut plantation possessed by HCCDI. Other government agencies submitted certifications indicating no opposition or encroachment on public properties. The MTC granted the application, finding sufficient evidence of possession. The Court of Appeals affirmed the MTC decision.

ISSUE

Whether the Court of Appeals erred in affirming the MTC’s grant of HCCDI’s application for land registration.

RULING

The Supreme Court granted the petition and reversed the decisions of the lower courts. The Court held that HCCDI failed to prove that the subject land was alienable and disposable. While the Land Management Office report stated the land was within an alienable and disposable zone classified on March 30, 1926, it did not establish that the land was officially declared alienable and disposable on or before that date, nor did it provide proof that such classification had been released to the public domain by a positive act of the government. The mere certification that the land is within the alienable and disposable zone per a 1926 classification is insufficient without evidence of an official government act reclassifying the land from forest to alienable agricultural land. Furthermore, HCCDI failed to present the original classification approved by the DENR Secretary or a certified true copy thereof, as required by jurisprudence. Consequently, HCCDI did not overcome the presumption that the land remains part of the inalienable public domain. The application for registration was therefore denied.