G.R. No. L-50340 December 26, 1984
DIRECTOR OF LANDS, petitioner, vs. COURT OF APPEALS, JOSE F. SALAZAR, JESUS F. SALAZAR, PEDRO F. SALAZAR and AURORA F. SALAZAR, respondents.

FACTS

The private respondents, the Salazar siblings, filed an application for the registration of a 291-hectare land in Pilar, Sorsogon. They claimed ownership through a 1952 sale from Tomas Cevallos and Alberta Cevallos Vda. de Vasquez to their mother, Soledad Fajardo Vda. de Salazar, and a subsequent 1965 sale from their mother to them. The land was declared alienable and disposable only on April 28, 1961. The application was opposed by the Director of Lands and twenty-five occupant-farmers.
A land inspector’s report revealed that numerous farmers and their predecessors had been in open, continuous, peaceful, and exclusive possession of various portions of the land for a long time, cultivating crops and building houses. These occupants refused to acknowledge the Salazars’ claim when informed in 1966. The Salazars’ evidence of possession rested on an alleged overseer who did not testify, and their tax declarations and receipts were found to be inconsistent, irrelevant, or not conclusively linked to the specific property.

ISSUE

Whether the Salazars have sufficiently proven their registrable title to the land under Section 48(b) of the Public Land Law, as amended.

RULING

No. The Supreme Court reversed the Court of Appeals’ 1979 resolution granting registration and reinstated its 1977 decision denying the application. The legal logic is anchored on the failure to meet the stringent requirements for judicial confirmation of imperfect title. First, for registration under Section 48(b), possession and occupation must be proven since June 12, 1945, or earlier. The land was classified as alienable only in 1961, meaning any possession prior to that date could not ripen into ownership as the land was not yet susceptible to private appropriation.
Second, the Salazars failed to prove the required open, continuous, exclusive, and notorious possession in the concept of an owner. The land inspector’s report, which the Court found credible, established that the actual possessors were the opposing farmers, not the applicants. The Salazars’ claim of possession through an overseer was unsubstantiated as the overseer did not testify. Their documentary evidence, particularly the tax declarations and receipts, was either irrelevant to the specific parcels or insufficient to overcome the concrete evidence of the occupants’ actual, physical possession. Tax declarations are not conclusive proof of ownership, especially when contradicted by evidence of third-party possession. Consequently, the Salazars did not discharge their burden of proof, and the land remains part of the public domain.