G.R. No. 237714, November 12, 2018
Republic of the Philippines, Petitioner, vs. Science Park of the Philippines, Inc., Respondent.

FACTS

Respondent Science Park of the Philippines, Inc. (SPPI) filed an application for original registration of a 7,691-square meter parcel of land in Malvar, Batangas. SPPI claimed the land was alienable and disposable and 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. To prove alienability, SPPI presented a CENRO certification and a copy of DENR Administrative Order (DAO) 97-37. To prove possession, it presented a chain of title tracing ownership from Gervacio Lat, who held a 1955 tax declaration, through subsequent sales culminating in SPPI’s purchase in 2013.
The Municipal Circuit Trial Court (MCTC) granted the application. It held that SPPI proved possession tacked to its predecessors and that the land was alienable. Notably, the MCTC took judicial notice of the authenticity of DAO 97-37 based on a stipulation from a prior, unrelated land case involving the same lawyers. The Republic appealed, arguing SPPI failed to prove alienability as no DENR official authenticated DAO 97-37, and failed to prove possession since June 12, 1945, as the earliest evidence was only a 1955 tax declaration. The Court of Appeals affirmed the MCTC decision.

ISSUE

Whether the Court of Appeals erred in affirming the grant of SPPI’s application for original registration of title.

RULING

Yes, the Court of Appeals erred. The Supreme Court reversed the CA decision and denied SPPI’s application for registration. For judicial confirmation of imperfect title under Section 14(1) of Presidential Decree No. 1529, an applicant must prove: (1) the land forms part of the alienable and disposable land of the public domain, and (2) the applicant and 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. SPPI failed to prove both requisites by clear and convincing evidence.
First, SPPI did not conclusively establish the land’s alienable and disposable status. While a CENRO certification is admissible, the accompanying DAO 97-37, which is the legislative act reclassifying the land, must be duly authenticated by its official custodian from the DENR. The MCTC improperly took judicial notice of DAO 97-37 based on a stipulation in a different case. Judicial notice cannot substitute for the required authentication; the rule demands the official custodian’s presentation to confirm the order’s existence and that it remains in force. SPPI’s failure to present such evidence is fatal.
Second, SPPI failed to prove possession since June 12, 1945. The earliest documentary evidence was a 1955 tax declaration in the name of Gervacio Lat. Tax declarations, while indicative of claim, are not conclusive proof of ownership. Testimonies regarding possession prior to 1955 were general and uncorroborated by any contemporaneous documentary evidence. The required possession must be substantiated by well-nigh incontrovertible proof. SPPI’s evidence merely established possession from 1955 onward, which is insufficient to meet the June 12, 1945 cutoff. Consequently, SPPI did not acquire an imperfect title susceptible to registration.