G.R. No. 189723 - Republic vs. AlamiNo.Ice Plant and Cold Storage, Inc.

On 17 August 2004, respondent Alaminos Ice Plant and Cold Storage, Inc., a domestic corporation, filed an application for the original registration of a 10,000-square meter piece of land in Barangay Pogo, Alaminos City under the Torrens system.
The land was identified as Lot No. 6411-B, Cad-325-D of Plan CSD-01-013782-D and described with specific boundaries delineated by adjacent roads, lot divisions, and identifiable landmarks (e.g., National Road and nearby lots from a subdivision plan).

The original claimants were Juan Duldulao and Leonora Duldulao, who conveyed the land to their daughter Mary Jane Almazan.
The tax declaration records showed continuous possession from 1951 until 1997 by the Duldulao family and Mary Jane Almazan.
Mary Jane Almazan sold the land to Rissa Santos Cai, from whom the respondent acquired the property in April 2002.
After acquisition, respondent enclosed the property with a concrete fence and constructed an ice plant, evidencing acts of occupation and control.

The application was docketed as Land Registration Case No. A-637 before Branch 54 of the Regional Trial Court (RTC) of Alaminos City.
During trial, the government oppositor, represented by the Director of Lands and the Solicitor General through City Prosecutor Abraham L. Ramos II, opposed the registration but failed to adduce evidence against the application.
The RTC found that respondent and its predecessors-in-interest had possessed the land openly, continuously, exclusively, and notoriously under a bona fide claim of ownership since 1951, and ruled in favor of granting registration based on the evidence presented (including tax declarations and possession acts).

Respondent failed to submit evidence proving that the subject land was alienable and disposable.
Respondent failed to prove that the requisite acts of possession had been performed for at least thirty (30) years.

In its brief dated 29 January 2009, respondent argued that the land was not in the public domain.
On 20 March 2009, respondent submitted a document titled “Manifestation/Compliance with Comment to Appellant’s Arguments” which included a certification from the Community Environment and Natural Resources Office (CENRO), dated 9 March 2009, attesting that the land was alienable and disposable.
The appellate court (Court of Appeals) relied solely on this CENRO certification in its affirmation of the RTC decision, concluding that the land was part of the alienable and disposable public domain.

The Republic, through its petition for review on certiorari, argued that the appellate decision improperly relied on the CENRO certification, which was both unoffered during trial and beyond the issuing authority’s competence given the land area.
The petition also contested that respondent did not sufficiently prove the required acts of possession within the legally mandated period.

Whether the certification issued by the CENRO, which was not formally offered during trial, could be given evidentiary value to establish that the subject land is alienable and disposable.
Whether relying solely on this certification satisfied the legal requisites for establishing the alienability and disposability of public domain lands.

Whether respondent and its predecessors-in-interest have demonstrated open, continuous, exclusive, and notorious possession since 1951, thereby meeting the statutory requirements for land registration under a bona fide claim.
Whether the evidence, namely the tax declarations and possession acts, was sufficient to maintain that the possession requirement was met.

Whether the burden of proving that the land is alienable and disposable lies with the applicant, as opposed to shifting the burden to the State to prove inalienability.