GR 233339; (February, 2019) (Digest)
G.R. No. 233339 , February 13, 2019
D.M. CONSUNJI, INC., Petitioner, vs. REPUBLIC OF THE PHILIPPINES and THE HEIRS OF JULIAN CRUZ, represented by MACARIA CRUZ ESTACIO, Respondents.
FACTS
Petitioner D.M. Consunji, Inc. (DMCI) filed an application for original registration of title over a parcel of land in Taguig City. DMCI claimed it acquired the land from Filomena San Pedro and that it and its predecessors-in-interest had been in open, continuous, exclusive, and notorious possession since June 12, 1945, or earlier. The Heirs of Julian Cruz opposed, asserting ownership through their predecessors since the 1920s, as evidenced by tax declarations. The Republic also opposed, arguing DMCI failed to prove the land was alienable and disposable and that it possessed the requisite period.
The Metropolitan Trial Court (MeTC) initially denied DMCI’s application, finding it failed to prove possession since 1945. Upon reconsideration, the MeTC reversed itself, granted the application, and confirmed DMCI’s title. The MeTC ruled that credible testimony could support the possession period and that the land was within an alienable and disposable zone per a submitted conversion plan and field inspection report.
ISSUE
Whether the Court of Appeals correctly reversed the MeTC Order and denied DMCI’s application for land registration.
RULING
Yes, the Court of Appeals was correct. The Supreme Court affirmed the CA’s denial of the application, holding that DMCI failed to satisfy the stringent requirements for original registration under Section 14(1) of Presidential Decree No. 1529. First, DMCI did not conclusively prove that the subject land was part of the alienable and disposable lands of the public domain. The evidence presented—a conversion plan and a field inspection report—was insufficient. Jurisprudence mandates that such classification must be established by a certified true copy of the original classification approved by the DENR Secretary and published in the Official Gazette or a newspaper of general circulation. DMCI’s evidence fell short of this standard.
Second, DMCI failed to prove that it and its predecessors-in-interest had been in open, continuous, exclusive, and notorious possession under a bona fide claim of ownership since June 12, 1945. The testimony of its predecessor, Filomena San Pedro, contained material inconsistencies regarding possession, and DMCI’s earliest tax declaration was only from 1995. This could not substantiate possession for the required period. The opposition and evidence presented by the Cruz heirs further undermined DMCI’s claim of exclusive possession. Consequently, DMCI did not acquire an imperfect title registrable under the law.