GR 70825; (March, 1991) (Digest)
G.R. No. 70825 ; March 11, 1991
DIRECTOR OF LANDS and DIRECTOR OF FOREST DEVELOPMENT, petitioners, vs. INTERMEDIATE APPELLATE COURT and ISIDRO ESPARTINEZ, respondents.
FACTS
Private respondent Isidro Espartinez applied for the registration of Lot 6783, alleging acquisition by purchase from Sotera Llacer. The government, through the Solicitor General, opposed, contending the land was part of the public domain and that Espartinez failed to prove the requisite possession. The trial court granted the application, finding that the land was originally adjudicated to Faustino Llacer in 1885 per an entry in the Gaceta de Manila, inherited by Sotera Llacer in 1913, and subsequently sold to Espartinez in 1969. Espartinez and his predecessors had declared the land for tax purposes and possessed it openly. The Intermediate Appellate Court affirmed, treating the 1885 adjudication as a possessory information title and allowing tacking of possession.
ISSUE
Whether the Court of Appeals erred in affirming the registration of title in favor of Isidro Espartinez.
RULING
The Supreme Court denied the petition and affirmed the appellate court’s decision. The legal logic centered on the application of Section 48(b) of the Public Land Act, as amended, which grants a conclusive presumption of a government grant after possession and occupation of alienable public land for at least thirty years. The Court held that the 1885 Gaceta de Manila entry constituted competent evidence of a Spanish title grant to Faustino Llacer, converting the land to private property. Consequently, the land was no longer part of the public domain subject to registration under the Public Land Act. Even assuming it was public land, the Court ruled that Espartinez successfully tacked his possession to that of his predecessors-in-interest, demonstrating open, continuous, exclusive, and notorious possession since 1885—far exceeding the 30-year requirement. The survey plan and technical description were deemed admissible, and the long-standing possession warranted confirmation of title, as the proceeding merely recognizes a vested right rather than conferring a new one.