G.R. No. 167652 - Limcoma Multi-Purpose Cooperative vs. Republic

On September 24, 2001, petitioner Limcoma Multi-Purpose Cooperative filed an application for registration and confirmation of title with the Regional Trial Court (RTC) of Rosario, Batangas for a parcel of land designated as Lot 972-A, No. Csd-04-015172-D, Cad 426, Rosario Cadastre, measuring 646 square meters.
The petitioner asserted that it is the owner in fee simple of the subject lot and the improvements thereon, having enjoyed open, exclusive, peaceful, and continuous possession for more than 30 years, calculated from the possession of its predecessors-in-interest.
In the alternative, the petitioner invoked Section 48 of the Public Land Act, as amended, arguing that the possession of the subject lot by itself and through its predecessors-in-interest had met the statutory requisites for registration.

The petitioner presented its evidence ex-parte before the Clerk of Court, who acted as Commissioner, and introduced key testimonies and documentary exhibits.

Olivia P. Gomez, the petitioner’s Assistant General Manager, testified about the acquisition of the subject lot from the Spouses Venustiano and Arsenia Alcantara on September 4, 1991, and established that the lot had been used as a sales and warehouse office.
Arsenia Alcantara testified regarding the historical ownership and possession of the land by her parents-in-law, the Spouses Andres and Trinidad, since 1938, and narrated how Lot 972 was later segregated into Lots 972-A and 972-B.
Lorenzo P. Limbo, a long-time resident familiar with the property and its owners, corroborated the continuous and exclusive possession of the subject lot by the Spouses Andres and Trinidad through his own personal observations and relationship with the family.

Documentary evidence included tax declarations (TD Nos. 00584 and 0452, referring to the missing TD No. 0884) and a Certification, as well as a DENR-CENRO Report dated September 23, 2002, which indicated:

The subject lot is not part of a military reservation or forest zone.
The land is classified as commercial and falls within the alienable and disposable zone.
No conflicting patents, decrees, or other claims exist over the subject lot.

The RTC issued an Order on April 10, 2003, granting the petition by holding that the petitioner had established possession in the concept of an owner, based on the consolidated evidence and testimonies.
On appeal, the Court of Appeals reversed and set aside the RTC decision, dismissing the petition by ruling that the petitioner had failed to demonstrate:

Open, continuous, exclusive, and notorious possession since June 12, 1945, as required by the Property Registration Decree and the Public Land Act.
The overcoming of the presumption that the subject lot is public and alienable land.

The petitioner argued that the possession of the subject lot, traced back to the Spouses Andres and Trinidad from 1938, and subsequently tacked through the donation to Venustiano in 1982, converted the public land into private property by the laws on acquisitive prescription.
The testimonies consistently emphasized the character of possession—open, exclusive, continuous, and in the concept of an owner—supported further by documentary evidence such as tax declarations and the DENR certification.

Determination of the true character of the subject lot in view of the DENR-CENRO Certification and Report.
Whether the evidence submitted sufficiently overcomes the presumption that the land is part of the public domain.

Whether the petitioner has been in open, continuous, exclusive, and notorious possession of the subject lot since June 12, 1945, or earlier.

Assessment of whether the possession of the subject lot by the Spouses Andres and Trinidad and its subsequent tacking through Venustiano satisfies the statutory requirement for original registration.
Evaluation of whether the petitioner’s possession for a subsequent period (10 years after the 1991 acquisition) meets the requirements for acquisitive prescription.

Whether the transformation of the subject lot from public to private land under the operation of the laws on prescription is valid.

Consideration of whether possession commencing in 1938 and continuing for over 30 years converts the status of the land.
Analysis of the legal effect of the alleged donation (even if void) and its impact on the chain of title based on good faith.