G.R. No. 220902, February 17, 2020
Republic of the Philippines, Petitioner, v. San Lorenzo Development Corporation (SLDC), Respondent.

FACTS

Respondent San Lorenzo Development Corporation (SLDC) filed an application for registration of two parcels of land in Compostela, Cebu, under Presidential Decree No. 1529. It alleged ownership by purchase in 1994 and 1995 and, together with its predecessors-in-interest, open, continuous, exclusive, and notorious possession and occupation for over 30 years. It presented testimonial and documentary evidence, including a Certification from the Community Environment and Natural Resources Office (CENRO) that the lands are within an alienable and disposable block per Forestry Administrative Order No. 4-1063 approved on September 1, 1965. The Regional Trial Court (RTC) granted the application, finding possession under a bona fide claim of ownership and that the lots are alienable and disposable. The Republic appealed, arguing failure to prove possession since June 12, 1945, as required under Section 14(1) of P.D. No. 1529. The Court of Appeals (CA) affirmed the grant but on a different ground, holding that while evidence was insufficient for Section 14(1), registration was proper under Section 14(2) as SLDC proved possession for more than 30 years and the lots were alienable and disposable. The CA denied the Republic’s motion for reconsideration, ruling the lands were converted into private properties through such possession.

ISSUE

Did the Court of Appeals err in granting SLDC’s application under Section 14(2) of P.D. No. 1529?

RULING

Yes. The Supreme Court granted the petition and denied SLDC’s application. The Court held that for any land registration, the applicant must first prove by clear and incontrovertible evidence that the land is alienable and disposable land of the public domain to overcome the presumption of State ownership under the Regalian Doctrine. SLDC failed to discharge this burden. The Certification from the CENRO was insufficient; the applicant must present a copy of the original classification approved by the DENR Secretary and certified as a true copy by the legal custodian to establish alienability and disposability. The fact that the Republic did not contest the alienability in its appeal does not constitute an admission or proof thereof. Since SLDC failed to prove this primary requisite, there was no necessity to discuss the other requirements for registration under Section 14(2) of P.D. No. 1529. The assailed CA Decision and Resolution were reversed and set aside.