G.R. No. 218345 . December 07, 2016.
Republic of the Philippines, Petitioner, v. The Estate of Virginia Santos, represented by Pacifico Santos, Respondent.

FACTS

The Estate of Virginia Santos filed an application for original land registration over a parcel of land in Taguig City under Section 14 of P.D. No. 1529. The estate claimed ownership through Virginia Santos, the sole heir of Alejandro Santos. It alleged that Virginia and her predecessor-in-interest had been in open, continuous, exclusive, and adverse possession of the property for over thirty years. To support its claim, the estate presented testimonies of tenants who stated their family had tilled the land since before World War II, along with tax declarations dating back to 1949. The Metropolitan Trial Court (MeTC) initially denied the application, finding the evidence insufficient to prove possession and the alienable status of the land. Upon motion for reconsideration, the MeTC reversed itself and granted the registration. The Court of Appeals affirmed this amended order.

ISSUE

Whether the respondent estate has sufficiently established all the requisites for the grant of its application for original registration of title.

RULING

No. The Supreme Court reversed the Court of Appeals and denied the application. For a successful registration under Section 14(1) of P.D. No. 1529, an applicant must prove: (1) the land forms part of the alienable and disposable agricultural land of the public domain; and (2) the applicant and his predecessors-in-interest have been in open, continuous, exclusive, and notorious possession and occupation under a bona fide claim of ownership since June 12, 1945, or earlier. The Court found the respondent estate failed on both counts. First, the certification on the survey plan stating the land was within an alienable zone per a 1968 classification was insufficient. The applicant must present a certified true copy of the original classification approved by the DENR Secretary, showing the land was declared alienable and disposable on or before June 12, 1945. Second, the evidence of possession was inadequate. The testimonies of the tenants, while indicating cultivation, did not conclusively establish the required possession in the concept of an owner since 1945. Tax declarations are not conclusive evidence of ownership. Without proof the land was alienable by 1945, acquisitive prescription could not run against the State. Therefore, the estate did not acquire an imperfect title. The denial was without prejudice, allowing the respondent to re-file if it can subsequently comply with all legal requirements.