G.R. No. L-5776, April 1, 1911
JOSE DENOGA, applicant-appellant, vs. THE INSULAR GOVERNMENT, opponent-appellee.

FACTS

Jose Denoga applied for the registration of a parcel of land in Moncada, Tarlac, claiming ownership based on his possession since 1894. He initially paid rent to the municipality, which claimed ownership. Later, a caretaker for a certain Pleming declared the land for tax purposes. Pleming failed to pay the land tax, leading the provincial treasurer to sell the land at public auction. Denoga purchased it, and after the redemption period lapsed without any claim, the treasurer issued him a certificate of title. No opposition was filed by the municipality, the Insular Government, or any other party despite due publication and notice.

ISSUE

Whether Denoga’s certificate of title issued by the provincial treasurer after a tax sale is sufficient for registration under the Land Registration Act, in the absence of any opposition impugning the validity of the sale.

RULING

Yes. The Supreme Court reversed the lower court’s denial of registration. In the absence of any opposition challenging the tax sale, Denoga’s certificate of title issued by the provincial treasurer constitutes a prima facie valid and registerable title. The Court distinguished this case from Valencia v. Jimenez and Fuster, where the owner appeared and contested irregularities in the tax sale proceedings. Here, since no party impugned the sale’s validity or claimed superior rights, Denoga’s title derived from the tax sale must be upheld. The general default following publication confirmed him as the sole legitimate owner. The application for registration was granted.