GR 214367; (April, 2018) (Digest)
G.R. No. 214367 APRIL 4, 2018
REPUBLIC OF THE PHILIPPINES, Petitioner vs LAUREANA MALIJAN-JAVIER AND IDEN MALIJAN-JAVIER, Respondents
FACTS
Respondents Laureana and Iden Malijan-Javier applied for original registration of title over a 9,629-square-meter parcel of land in Talisay, Batangas. They claimed open, continuous, exclusive, and notorious possession in the concept of an owner since June 12, 1945, through themselves and their predecessors-in-interest. To prove the land was alienable and disposable, they presented a DENR-CENRO certification stating the land was within an alienable and disposable zone under Project No. 39, per Land Classification Map No. 3553 certified on September 10, 1997. The Municipal Circuit Trial Court granted their application, a decision affirmed by the Court of Appeals.
The Republic opposed, arguing the respondents failed to sufficiently prove the land’s alienable and disposable character. The petitioner specifically contended that the mere presentation of the CENRO certification was inadequate, as it was not the original classification approved by the DENR Secretary and certified by the legal custodian of the official records.
ISSUE
Whether the respondents successfully established that the subject land is alienable and disposable public land, thus registrable in their names.
RULING
No. The Supreme Court reversed the lower courts’ decisions and denied the application for registration. The Court reiterated the stringent requirement for proving that land of the public domain is alienable and disposable. Applicants must present a copy of the original classification approved by the DENR Secretary and certified as a true copy by the legal custodian of the official records. This requisite, established in Republic v. T.A.N. Properties, serves as conclusive proof of the land’s legal status.
In this case, the respondents only submitted a CENRO certification. While such a certification may constitute prima facie evidence, it is not the specific document mandated by prevailing jurisprudence. The certification merely states the land is within an alienable zone but does not constitute the certified true copy of the original DENR Secretary’s classification. This failure to present the required documentary evidence is fatal to their application. Consequently, without conclusive proof that the land is alienable and disposable, the respondents cannot register title over it, regardless of the length or quality of their alleged possession. The burden of proof rests on the applicants, and they did not discharge this burden with the requisite evidence.