G.R. No. 166865 - Buenaventura vs. Republic

Petitioners: Angelita F. Buenaventura and Preciosa F. Buenaventura, heirs of spouses Amado Buenaventura and Irene Flores, who acquired a parcel of land from the heirs of Lazaro de Leon before World War II.
Acquisition Details:

The spouses executed a Deed of Sale on January 30, 1948, and transferred the tax declaration from the original owners to themselves.
In 1978, the spouses transferred the property to their children, which included petitioners, resulting in a new tax declaration being issued in the names of the children.

Petitioners filed an application on June 5, 2000, at the Regional Trial Court (RTC) of ParaAaque City for the subject property, described as Cadastral Lot No. 5001-B in ParaAaque Cadastre.
The petitioners asserted that they and their predecessors acquired title by inheritance, transfer, and long possession.

The RTC set the case for hearing and ordered proper notice to be published and served in compliance with Section 23 of the Property Registration Decree.
At the initial hearing (September 27, 2001), no interested party other than the petitioners appeared, prompting the RTC to declare a general default (except for the Republic).

Petitioners presented documentary evidence (deeds, tax declarations, cadastral maps) and five witnesses to demonstrate continuous, open, exclusive, and notorious possession in the concept of an owner for over 50 years.
Evidence aimed to prove fee simple title, nature of possession, alienable and disposable status of the land, improvements on the land, and payment of taxes.

On October 29, 2001, the RTC issued an Order confirming and registering the petitioners’ title to the subject property pending final judgment.
This Order included directives for the issuance of a registration decree and notifications to adjacent owners and concerned government agencies.

The Republic of the Philippines, through its counsel, appealed the RTC Order on the ground that petitioners failed to prove possession since June 12, 1945, and that the property was inherently public land given its classification under the Regalian Doctrine and relevant constitutional provisions.
The Republic argued that the evidence only substantiated possession beginning in 1948 and that the property did not meet the requirement of early possession as mandated by the Property Registration Decree.

On August 23, 2004, the CA reversed the RTC decision, setting aside the registration Order and declaring the subject property public land.
On January 25, 2005, the CA denied the petitioners’ Motion for Reconsideration on an identical premise, reinforcing its earlier finding.

The petitioners submitted a certification from the Department of Environment and Natural Resources (DENR) verifying that the property was alienable and disposable, validated by the relevant forestry administrative order.
Further evidence such as tax declarations, receipts for real property taxes, and witness testimonies bolstered the claim of open, continuous, exclusive, and notorious possession.

Petitioners maintained that the evidence clearly demonstrated their eligibility for registration by proving that their possession (from the date of classification as alienable and disposable) extended for more than 30 years.
They argued that even though possession commenced in 1948, the legal framework allowed registration under prescription (Section 14[2] of the Property Registration Decree).

Whether the RTC’s findings of open, continuous, exclusive, and notorious possession were supported by substantial evidence given that petitioners could only show possession from 1948, not from June 12, 1945, as required by Section 14(1) of the Property Registration Decree.
Whether the possession prior to the land being declared alienable and disposable (i.e., prior to January 3, 1968) should count toward the required period for acquiring title by prescription.

Whether the certification by the DENR establishing that the subject property is alienable and disposable sufficiently rebutted the presumption that it was public land under the Regalian Doctrine.
Whether the application for registration should be entertained under Section 14(2) of the Property Registration Decree, which allows title by prescription despite the possession period commencing after June 12, 1945.

Whether the CA erred in reversing the RTC’s Order by dismissing the petitioners’ evidence regarding possession and inappropriately declaring the land public.
Whether the CA’s reliance on the starting date of possession (June 12, 1945) rather than the actual date of classification as alienable and disposable (January 3, 1968) constituted a grave error.