G.R. No. 193305 - Republic vs. Banal na Pag-aaral, Phil., Inc.

Respondent Banal na Pag-aaral, Phil., Inc. filed an Amended Application for Registration for Lot Nos. 2304 and 2312 (consolidated as Lot No. 9404) covering 57,989 square meters situated in Barangay Dagatan, Amadeo, Cavite.
The application was filed with the Regional Trial Court (RTC) under Land Registration Case No. TG-898, asserting that the respondent holds actual possession and ownership of the subject lot.

Respondent’s claim is grounded on the history of continuous, exclusive, and notorious possession performed in the concept of an owner.
The possession traceably began long before World War II, purportedly inherited from predecessors-in-interest—the Heirs of Hermogenes Bayot—whose extrajudicial partition of estate and subsequent Deed of Absolute Sale dated September 4, 1997 conveyed the property.
Documentary evidence submitted by the respondent included:

A Certification dated May 22, 2002, issued by the DENR’s Community Environment and Natural Resources Office (CENRO) confirming that the subject lot is not covered by any public land application.
A copy of an approved Consolidated Plan with a notation indicating that the survey over the subject lot was done “inside alienable and disposable area” in accordance with Land Classification Map No. 3013.

Additional proof of possession, dating from the early 1940s, was established through documentary evidence (e.g., tax declarations) and testimony:

The RTC rendered a Decision on April 1, 2003, approving the applicant’s registration by finding that the respondent had sufficiently established both its possession and the alienable and disposable nature of the subject lot.
Petitioner (the Republic) challenged this ruling and, in a CA Decision dated July 6, 2009, the Court of Appeals (CA) reversed the RTC’s decision and set aside the registration application for failing to prove that the lot was alienable and disposable.
Respondent, moving for reconsideration, submitted additional documents:

A CENRO Certification dated December 9, 2008 indicating that the land falls within the alienable and disposable classification under Project No. 5 per Land Classification Map No. 3013.
A certified copy of FAO No. 4-1656 issued by the then-Minister of Natural Resources.

The CA, in an Amended Decision dated January 8, 2010, vacated its previous ruling, thereby affirming the RTC decision and approving respondent’s application for registration.
Petitioner further contested this decision, filing a motion for reconsideration which was denied by the CA in its Resolution dated August 3, 2010.
The case was eventually remanded by the Supreme Court in a Resolution dated February 5, 2018, directing the CA to verify the authenticity and due execution of the contested CENRO Certification, with the CA subsequently reaffirming its findings in a Report and Recommendation dated June 25, 2019.

Whether the respondent has maintained the requisite open, continuous, exclusive, and notorious possession of the subject lot for the duration mandated by law (i.e., since June 12, 1945 or earlier).
Whether the respondent has sufficiently established that the subject lot is part of the alienable and disposable lands of the public domain.
Whether the documentary evidence, including the CENRO Certification and the certified FAO No. 4-1656, is adequate to overcome the presumption that the property remains state-owned.