G.R. No. L-57573 July 5, 1982
DIRECTOR OF LANDS, petitioner, vs. ERNESTO DATU, CONSUELO VALENZUELA and COURT OF APPEALS, respondents.

FACTS

The spouses Ernesto Datu and Consuelo Valenzuela applied for the registration of Lot No. 2027-B, a 24,573-square-meter parcel in Samal, Bataan. The Director of Lands opposed, asserting the land was already declared public land in a prior cadastral proceeding where the court, in 1946, adjudicated it as government property subject to a homestead application by Mariano Siasat. The applicants claimed ownership through possession, alleging that Ernesto Datu had possessed the land openly and adversely since 1950, when he purportedly purchased it from Cipriano Penaflor, who had allegedly possessed it since 1938. However, the deed of sale was executed only in 1974. Datu presented tax declarations only from 1972 onward and paid realty taxes only for 1972-1974. His testimony was unclear on when the land was converted from cogon land to sugarcane land, and a Bureau of Lands investigator reported it as cogon land in late 1974. The applicants did not present Penaflor, any alleged tenant, or other corroborative witnesses to substantiate the claimed possession and cultivation.
Both the trial court and the Court of Appeals ordered the registration of the land in favor of the Datu spouses, ruling they and their predecessor had possessed it for over thirty years, thereby acquiring an imperfect title confirmable under Section 48(b) of the Public Land Law.

ISSUE

Whether the evidence presented by the applicants is sufficient to establish open, continuous, exclusive, and notorious possession of the land in the concept of an owner for at least thirty years to justify judicial confirmation of an imperfect title.

RULING

The Supreme Court reversed the decisions of the lower courts and declared the lot part of the public domain. The legal logic centers on the stringent evidentiary requirements for judicial confirmation of imperfect title under the Public Land Law. Possession must be proven by clear and convincing evidence, characterized by acts of ownership such as cultivation, payment of taxes, and exclusivity over a significant period. The Court found the applicants’ evidence nebulous and insufficient. Critical deficiencies included: the late tax declaration (only from 1972) and tax payments; the absence of the predecessor-in-interest, Penaflor, to testify on his alleged possession since 1938; the lack of any tenant or independent witness to corroborate possession and cultivation; the ambiguity regarding when the land was actually cultivated; and the official report indicating the land remained uncultivated cogon land as of 1974. These gaps failed to substantiate a claim of thirty years of possession en concepto de dueño. Consequently, the presumption that the land remained part of the public domain was not overcome. The State retains ownership unless a grant is unequivocally proven, and no such implied grant could be deduced from the insubstantial evidence presented.