G.R. No. 205641 , October 05, 2022
Superior General of the Religious of the Virgin Mary (R.V.M.), Petitioner, vs. Republic of the Philippines, Respondent.

FACTS

The Religious of the Virgin Mary (RVM), a religious congregation, filed an application for original registration of a 4,539-square meter parcel of land in Borongan, Eastern Samar. RVM alleged it acquired the lot through sales and donations from 1946 to 1953 and had since used it for St. Joseph’s College. It claimed open, continuous, exclusive, and notorious possession under a bona fide claim of ownership for over thirty years. The Republic opposed, arguing RVM failed to prove possession since June 12, 1945, and that the land remained part of the public domain. The trial court granted the application, finding RVM proved ownership since 1946.
The Court of Appeals reversed the trial court’s decision. It ruled that while RVM proved possession from 1946, this was insufficient as the law requires possession since June 12, 1945, or earlier. The CA also found the evidence on the alienable status of the land inadequate. RVM elevated the case to the Supreme Court via a petition for review on certiorari.

ISSUE

Whether the petitioner, RVM, has sufficiently established its right to original registration of the subject land under either the Public Land Act or the Property Registration Decree.

RULING

The Supreme Court denied the petition and affirmed the Court of Appeals’ decision. The Court held that for original registration under Section 14(1) of the Property Registration Decree, an applicant must prove: (a) the land forms part of the alienable and disposable agricultural land of the public domain; (b) the applicant and its predecessors-in-interest have been in open, continuous, exclusive, and notorious possession and occupation; and (c) such possession is under a bona fide claim of ownership since June 12, 1945, or earlier. RVM failed to meet this burden. Its earliest evidence of possession dated only to 1946, falling short of the critical June 12, 1945, cutoff. Testimonies and deeds only traced possession to 1946, not prior. Furthermore, the certification from the Community Environment and Natural Resources Office (CENRO) presented by RVM merely stated the land was within an alienable and disposable zone but did not categorically confirm its status as such on or before June 12, 1945. A CENRO certification is insufficient; a certification from the Department of Environment and Natural Resources (DENR) Secretary or a duly authorized representative is required to establish the land’s alienable and disposable character at the required time. Consequently, RVM did not overcome the presumption that the land remains part of the inalienable public domain. The Court also clarified that the constitutional prohibition against religious corporations acquiring alienable lands of the public domain, except by lease, was not the primary basis for denial, as the application failed on the fundamental grounds of insufficient proof of possession since June 12, 1945, and of the land’s alienable status.