G.R. No. 203090. September 05, 2018
KAWAYAN HILLS CORPORATION, PETITIONER, V. THE HONORABLE COURT OF APPEALS, JUSTICES JUAN ENRIQUEZ, JR., APOLINARIO BRUSELAS, JR., MANUEL BARRIOS, AMELITA G. TOLENTINO, AND THE REPUBLIC OF THE PHILIPPINES, RESPONDENTS.

FACTS

Kawayan Hills Corporation filed an application for judicial confirmation of imperfect title over a 1,461-square-meter parcel of land in Paoay, Ilocos Norte. It claimed to have acquired the lot in 1995 from the successors-in-interest of Andres Dafun, who had been the tax declarant since 1931. Kawayan Hills presented tax declarations, a CENRO certification that the land was alienable and disposable, and testimonial evidence from Andres Dafun’s grandson, Eufemiano, who testified that his grandfather had possessed and cultivated the land since World War II. The Municipal Circuit Trial Court granted the application, finding that the continuous tax declarations coupled with actual possession since 1945 or earlier warranted confirmation of title.
The Republic, through the Office of the Solicitor General, appealed to the Court of Appeals. The appellate court reversed the trial court, ruling that Kawayan Hills failed to prove the requisite possession and occupation since June 12, 1945. It held that tax declarations are not conclusive evidence of ownership and that the applicant’s evidence, particularly the grandson’s testimony, was insufficient to establish the specific character and duration of possession required by law. Kawayan Hills then filed this Petition for Certiorari under Rule 65, alleging grave abuse of discretion by the Court of Appeals.

ISSUE

Whether the Court of Appeals committed grave abuse of discretion in reversing the trial court’s decision and denying the application for confirmation of imperfect title.

RULING

Yes. The Supreme Court granted the petition, reinstating the trial court’s decision. The Court emphasized that while tax declarations alone are not conclusive proof of ownership, they constitute good indicia of possession in the concept of an owner. When coupled with actual, continuous, and open possession, they form strong evidence of title. The Court found that the Court of Appeals erred in mechanically dismissing the probative value of the tax declarations and in failing to consider the totality of evidence presented.
The legal logic centers on the proper evaluation of evidence for judicial confirmation of title under Section 14(1) of Presidential Decree No. 1529. The Court held that the appellate court disregarded established jurisprudence which recognizes that payment of real property taxes, especially when dated from the pre-war period, is a significant indicator of ownership claims. Here, the tax declaration in the name of the predecessor-in-interest dated back to 1931. This documentary evidence was corroborated by the uncontroverted testimonial evidence of actual cultivation and possession by the Dafun family, which the trial court found credible. The Court of Appeals’ dismissal of the grandson’s testimony as insufficient was a capricious disregard of competent evidence, constituting grave abuse of discretion. The Supreme Court concluded that Kawayan Hills, through its predecessors-in-interest, had satisfactorily proven open, continuous, exclusive, and notorious possession and occupation of the alienable and disposable land under a bona fide claim of ownership since June 12, 1945, if not earlier.