G.R. No. 248306, June 28, 2021
Republic of the Philippines, Petitioner, vs. Science Park of the Philippines, Inc., rep. by its Executive Vice-President and Gen. Manager, Mr. Richard Albert I. Osmond, Respondents.

FACTS

On September 3, 2015, respondent Science Park of the Philippines, Inc. filed an application for original registration of title over a 5,255-square meter parcel of land (Lot No. 3394) in Malvar, Batangas, under Section 14(1) of Presidential Decree No. 1529 (PD 1529). It claimed ownership acquired from Antonio Aranda via a 2014 Deed of Absolute Sale and asserted that it and its predecessors-in-interest had been in open, continuous, exclusive, and notorious possession since June 12, 1945 or earlier. The Municipal Circuit Trial Court (MCTC) granted the application. The Republic, through the Office of the Solicitor General (OSG), appealed, arguing respondent failed to prove possession since June 12, 1945, and that the land, being public domain, could not be acquired by prescription without a government declaration converting it to patrimonial property under Article 422 of the Civil Code. The Court of Appeals affirmed the MCTC decision, holding that the requirements of Article 422 apply only to applications under Section 14(2) of PD 1529, and that respondent sufficiently proved compliance with Section 14(1).

ISSUE

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

RULING

No, the Court of Appeals did not err. The Supreme Court denied the petition and affirmed the assailed Decision and Resolution of the Court of Appeals. The Court held that respondent’s application was anchored on Section 14(1) of PD 1529, which requires: (1) that the land forms part of the disposable and alienable lands of the public domain; and (2) that the applicant and its 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 that respondent satisfactorily proved these elements. The alienable and disposable character of the land was established through a Land Classification Map and a DENR Administrative Order. Possession since June 12, 1945 was proven through testimonial evidence, particularly from witness Eliseo Garcia, who attested to the ownership and possession by respondent’s predecessors since before World War II, and through documentary evidence tracing the chain of ownership. The Court clarified that the requirement under Article 422 of the Civil Code—that property of public dominion must first be declared patrimonial before it can be acquired by prescription—applies only to applications based on Section 14(2) of PD 1529 (acquisition by prescription), not to those based on Section 14(1) (possession since June 12, 1945). Since respondent relied on Section 14(1), it did not need to prove such a government declaration.