G.R. No. 57667 May 28, 1990
SAN MIGUEL CORPORATION, petitioner, vs. COURT OF APPEALS and DIRECTOR OF LANDS, respondents.

FACTS

Petitioner San Miguel Corporation (SMC) purchased a 14,531-square-meter parcel of land in Batangas from Silverio Perez in 1975. In 1977, SMC filed an application for registration of the land under the Land Registration Act, claiming ownership in fee simple. The Republic, through the Solicitor General, opposed the application, contending the land was part of the public domain and that SMC, as a private corporation, was constitutionally disqualified from holding alienable lands of the public domain. The trial court granted SMC’s application.
The Court of Appeals reversed the trial court’s decision, declaring the land as public land. The appellate court found SMC’s evidence insufficient to establish a registrable title. SMC then elevated the case to the Supreme Court via petition for review, arguing that the Court of Appeals erred in disregarding its evidence and reversing the trial court’s factual findings.

ISSUE

Whether the evidence presented by SMC is sufficient to warrant a ruling that it, or its predecessor-in-interest, has acquired a registrable title over the subject land through prescription.

RULING

The Supreme Court denied the petition and affirmed the decision of the Court of Appeals. The Court held that while open, exclusive, and undisputed possession of alienable public land for the period prescribed by law can convert it into private property, such possession must be conclusively established. SMC failed to meet this quantum of proof.
SMC’s claim of possession rested primarily on tax declarations and the uncorroborated testimony of its vendor, Silverio Perez. Tax declarations and receipts are not conclusive evidence of ownership; they are merely indicia of a claim of ownership. They only become strong evidence of ownership acquired by prescription when accompanied by proof of actual possession. Here, Perez’s testimony that he and his parents possessed the land since 1925 was self-serving and lacked corroboration. SMC’s other witness only testified regarding the corporation’s capacity to own property and its possession after the 1975 purchase, not the nature and duration of Perez’s prior possession.
Consequently, there was a paucity of evidence to establish the open, continuous, exclusive, and notorious possession of the land by SMC’s predecessor-in-interest for the required statutory period. Without such conclusive proof, the land remains part of the public domain, and SMC’s application for registration was properly denied.