G.R. No. 255266 , April 21, 2025
Republic of the Philippines, Petitioner, vs. Eduardo Manahan, Respondent.

FACTS

Respondent Eduardo Manahan filed an application for original land registration over three parcels of land in San Mateo, Rizal. He claimed ownership through a 2002 deed of sale from Lourdes Manahan, who acquired the lots from her siblings. The property was originally owned by Mariano Manahan, with possession purportedly dating back to his 1948 tax declaration. Eduardo presented testimonial evidence that he and his predecessor-in-interest, Filomena Manahan, cultivated the land since his childhood. To prove the land’s alienable and disposable status, he submitted an Advance Plan prepared by a DENR geodetic engineer, which contained an annotation referencing Land Classification Map No. 639 certified on March 11, 1927, and supporting certifications from the CENRO and PENRO.
The Municipal Trial Court (MTC) granted the application, finding that Eduardo proved all requisites for registration under Section 14(1) of Presidential Decree No. 1529, including open, continuous, exclusive, and notorious possession since June 12, 1945, or earlier, and that the lands were alienable and disposable. The Court of Appeals affirmed this decision. The Republic, through the Office of the Solicitor General, elevated the case via a Petition for Review on Certiorari, arguing that the evidence for alienability was insufficient.

ISSUE

Whether the Court of Appeals erred in affirming the grant of Eduardo Manahan’s application for original land registration.

RULING

The Supreme Court granted the petition and reversed the lower courts’ decisions. The Court held that Eduardo Manahan failed to conclusively prove that the subject lands were classified as alienable and disposable agricultural lands of the public domain. While the Advance Plan and the CENRO and PENRO Certifications referenced Land Classification Map No. 639, these documents were insufficient. The Advance Plan is merely a plotting of technical data and does not constitute a positive government act classifying land. The certifications, which merely verified the lots were “within” an area classified as alienable and disposable per a 1927 map, were also inadequate.
Crucially, the applicant did not present a certified true copy of Land Classification Map No. 639 itself, nor any official proclamation, executive order, or administrative action issued by the DENR Secretary formally declaring the specific parcels as alienable and disposable. The law requires that the classification as alienable and disposable must be established by positive act of the government, and the burden of proof rests on the applicant. The mere annotation on a survey plan and derivative certifications do not satisfy this stringent requirement. Consequently, one of the essential requisites for original registration was not met, warranting the denial of the application.