G.R. No. 224389 , November 07, 2018
Highpoint Development Corporation, Petitioner, vs. Republic of the Philippines, Respondent.

FACTS

Petitioner Highpoint Development Corporation filed an application for original registration of title over a 43,919-square-meter parcel of land in Lilo-an, Cebu, under Presidential Decree No. 1529. To establish its claim, petitioner presented witnesses and documentary evidence, including tax declarations dating back to 1945 in the names of its predecessors-in-interest and a Certification from the Community Environment and Natural Resources Office (CENRO) stating the land was within an alienable and disposable zone classified as such since July 31, 1940. The Regional Trial Court granted the application, finding petitioner had proven the requisite possession and the alienable status of the land.
The Republic appealed, arguing petitioner failed to sufficiently prove the land was alienable and disposable and that possession for the required period was established. The Court of Appeals reversed the RTC, holding that the CENRO Certification alone was insufficient to prove the land’s alienable status, as jurisprudence requires additional evidence, specifically a certified true copy of the original DENR classification approved by the Secretary. The CA also found the evidence of possession inadequate. Petitioner’s motion for reconsideration was denied.

ISSUE

Whether the Court of Appeals erred in denying the application for registration on the grounds of insufficient proof that the subject land is alienable and disposable public land and of inadequate evidence of possession.

RULING

The Supreme Court denied the petition and affirmed the Court of Appeals. The core legal logic centers on the stringent requirements for proving that land is alienable and disposable. For original registration under Section 14(1) of P.D. No. 1529, an applicant must conclusively establish that the land has been classified as alienable and disposable by the State. Jurisprudence, particularly Republic v. T.A.N. Properties, Inc., mandates that this must be proven by a certified true copy of the original classification approved by the DENR Secretary and attested by the legal custodian of the records. A mere CENRO certification is insufficient; it only verifies the status based on a survey and does not constitute the official declaration itself. The Court rejected petitioner’s argument for a pro hac vice (for this occasion only) exception or a revisit of the established rule, emphasizing that the rule is clear and intended to prevent the fraudulent registration of inalienable public land. Compliance with this evidentiary requirement is jurisdictional.
Regarding possession, the Court found no reason to depart from the CA’s findings. Since the fundamental requirement of alienability was not met, the application must fail. The tax declarations and testimonial evidence, while indicative of possession, cannot cure the fatal defect in failing to prove the land is registrable in character. The denial of the application was therefore proper.