G.R. No. 254433 , April 17, 2024
ARLO ALUMINUM CO., INC., PETITIONER, VS. REPUBLIC OF THE PHILIPPINES, RESPONDENT.

FACTS

Petitioner Arlo Aluminum Co., Inc. (Arlo) filed an application for registration of title over Lot Nos. 7948 and 7947 in Pasig City. Arlo claimed to have acquired the lots in 1996 and 1997 from Melvin Atienza and Dalisay Crisostomo, respectively, who in turn acquired them from Esmeraldo Tambongco. Arlo asserted that Tambongco and his successors-in-interest had been in continuous, open, public, and adverse possession in the concept of an owner since June 12, 1945, or earlier. Arlo submitted various documents, including survey plans, tax declarations, tax clearances, and two Certifications dated September 27, 2013, from the DENR-NCR signed by Regional Executive Director Neria A. Andin. These certifications stated the lots were verified to be within alienable or disposable land under Project No. 21 of Pasig per Land Classification Map No. 639, approved on March 11, 1927. Arlo presented three witnesses: Rosanna M. Santiago (authorized officer), Ronilo B. Jubacon (Vice President for Technical Services), and Caronia L. Murcia (DENR Records Officer). The Regional Trial Court (RTC) granted Arlo’s application, finding it and its predecessors-in-interest had been in open, continuous, and exclusive possession since prior to 1945. The Republic, through the OSG, appealed. The Court of Appeals (CA) reversed the RTC, ruling that Arlo failed to prove the lots were alienable and disposable lands of the public domain because it did not present a certified true copy of the DENR’s original classification. The CA also held Arlo failed to prove its predecessors-in-interest possessed the property in an open, continuous, exclusive, and notorious manner since June 12, 1945, or earlier. Arlo’s motion for reconsideration was denied, prompting this Petition for Review on Certiorari.

ISSUE

Did Arlo sufficiently prove that it is entitled to a decree of registration over the subject lots?

RULING

No, the Supreme Court did not rule on the sufficiency of Arlo’s proof. In view of new legal and jurisprudential developments during the pendency of the case, the Court resolved to remand the matter to the appellate court for the reception of new evidence. The Court noted that while it generally does not review factual findings, exceptional circumstances warrant a remand. Specifically, the Court cited the enactment of Republic Act No. 11573 , which amended Section 14(1) of Presidential Decree No. 1529 (Property Registration Decree). The amendment now allows applicants, under certain conditions, to apply for original registration of alienable and disposable lands of the public domain based on possession since June 12, 1945, “or earlier” (removing the previous “or earlier” qualification). Furthermore, recent jurisprudence, such as Republic v. Spouses Tan, has clarified the requirements for proving the alienable and disposable character of land. Given these significant changes in the law and jurisprudence that occurred after the CA rendered its decision, the Supreme Court found it proper to remand the case to the CA. This will allow Arlo the opportunity to present new evidence to establish compliance with the current legal requirements for original land registration. The CA is directed to receive such evidence and resolve the case with deliberate dispatch.