G.R. No. 37435; November 28, 1934
Numeriano Padilla, applicant-appellee, vs. Pablo Reyes and The Director of Lands, oppositors-appellants.

FACTS

Numeriano Padilla applied for the registration under the Torrens system of a 161-hectare parcel of land in Nueva Ecija. The Director of Lands and several homesteaders opposed, claiming the land was public. Pablo Reyes also opposed, claiming exclusive ownership. The trial court dismissed all oppositions and decreed registration in Padilla’s name. The oppositors appealed, though Reyes’s appeal was later dismissed. Padilla claimed ownership by inheritance, asserting his ancestors had possessed the land since the Spanish regime, using it for cultivation and pasture. The oppositors presented evidence that the land was unoccupied and without signs of cultivation when homesteaders settled there from 1912 to 1918, and that Padilla only disturbed their possession in 1927.

ISSUE

Whether Padilla had sufficiently established his title to the land to warrant its registration under the Torrens system.

RULING

No. The Supreme Court reversed the trial court’s decision. The applicant for land registration bears the burden of proving absolute ownership in fee simple. Padilla presented no valid title deed. He also failed to prove the requisite open, continuous, exclusive, and notorious possession by himself or his predecessors since July 26, 1894, which would give rise to a conclusive presumption of a government grant. The evidence showed the land was public and unoccupied when homesteaders entered. Therefore, the land remains public land and cannot be registered in Padilla’s name.

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