G.R. No. L-35778 & L-35779. January 27, 1983
REPUBLIC OF THE PHILIPPINES and THE DIRECTOR OF LANDS, petitioners, vs. HON. ABRAHAM P. VERA, Judge, CFI, Bataan, Branch I, and LUISITO MARTINEZ and THELMA TANALEGA, respondents.

FACTS

In two separate land registration cases, respondents Luisito Martinez and Thelma Tanalega applied for judicial confirmation of their titles over parcels of land in Mariveles, Bataan. Martinez applied for a 323,093-square-meter parcel, while Tanalega applied for two parcels with a combined area of over 821,000 square meters. The Republic, through the Director of Lands, opposed both applications, asserting the lands were part of the public domain. During the proceedings, it was established that the subject lands were portions of Lot No. 626 of the Mariveles Cadastre.
The trial court granted the applications. It found that the applicants and their predecessors-in-interest had possessed the lands openly, continuously, and in the concept of owners since 1938 or earlier, cultivating portions with palay, mango trees, and other crops. The court held this possession constituted a vested right, ripening into private ownership, and ordered the registration of the titles.

ISSUE

Whether the respondents have acquired a registrable title to the subject lands.

RULING

No. The Supreme Court reversed the trial court’s decisions, holding that the respondents failed to establish registrable title. The legal logic is twofold. First, the doctrine of res judicata bars the claims. The lands were part of a cadastral proceeding, which is a proceeding in rem that binds the whole world. The final judgment in that cadastral case, which presumably declared the lands as public domain, precludes the re-litigation of their status. Respondents cannot now assert ownership over the same parcels.
Second, even assuming the claims were not barred, the evidence of possession was insufficient. The applicants’ own testimony showed only portions of the vast areas applied for were cultivated. Mere casual or sporadic cultivation does not constitute the exclusive, notorious, and continuous possession in the concept of owner required by law for a grant from the State. Possession of public land, no matter how long, never confers title unless it complies with the specific statutory conditions for a judicial confirmation of imperfect title. Furthermore, the survey plans submitted were not approved by the Director of Lands as required by law, but by the Land Registration Commission, which lacked the authority to approve original survey plans for this purpose. The applications were therefore deficient.