G.R. No. 209462 , July 15, 2020
Ususan Development Corporation, represented by Atty. Roel A. Pacio, Petitioner, vs. Republic of the Philippines, Respondent.

FACTS

Petitioner Ususan Development Corporation (now DMCI Project Developers, Inc.) filed an application for registration and confirmation of title over a 3,975-square meter parcel of land in Taguig City. It claimed the land was originally owned by Jose Carlos, inherited by his daughter Maria Carlos upon his death in 1948, and subsequently sold to the petitioner in 1996. The petitioner and its predecessors-in-interest allegedly possessed the land openly, exclusively, continuously, and notoriously in the concept of an owner since June 12, 1945. To prove the land was alienable and disposable, petitioner presented a 2007 Certification from a DENR Regional Technical Director and a Taguig City Land Registration Case Map approved in 1968. The Regional Trial Court (RTC) granted the application. The Republic, through the Office of the Solicitor General, appealed, arguing the land remained part of the public domain and that the certification presented was not competent evidence. The Court of Appeals (CA) reversed the RTC, dismissing the application. Petitioner filed a Motion for Reconsideration with the CA, attaching new documents: a DENR Administrative Order on delegation of authority, a Certification from the Director of Forestry, and a Certified True Copy of Approved Land Classification Maps. The CA denied the motion, finding the new documents insufficient and not pertaining to the specific subject lot. Petitioner then filed the present Petition for Review on Certiorari.

ISSUE

Whether the Court of Appeals committed an error of law in reversing the RTC Decision and dismissing the application for original registration of title.

RULING

The Petition is denied. The Supreme Court affirmed the CA Decision and Resolution. The core issue was the petitioner’s failure to prove that the subject land is alienable and disposable land of the public domain, a mandatory requirement for original registration under Section 14(1) of Presidential Decree No. 1529. The CA correctly found the evidence initially presented (the 2007 DENR Certification and the 1968 map) insufficient. The new documents submitted for the first time on motion for reconsideration before the CA were properly rejected as they did not conclusively establish the land’s classification status and, critically, were found by the CA not to pertain to the specific lot in question. The Supreme Court, in a Rule 45 petition, is not a trier of facts and found no reason to disturb the CA’s factual findings on the inadequacy of the evidence. Since the petitioner failed to discharge the burden of proving the alienable and disposable character of the land, the application for registration was properly dismissed.