G.R. No. 163766 - Republic vs. Candy Maker, Inc.

In 1998, Candy Maker, Inc. purchased Lot No. 3138 of the Cainta-Taytay Cadastre, located below the reglementary lake elevation of 12.50 meters, approximately 900 meters from Laguna de Bay.
The property was subdivided by Geodetic Engineer Potenciano H. Fernandez into two lots:

Technical descriptions and subdivision plans were duly prepared, signed, and approved by the appropriate government agencies, including the Regional Technical Director of the Bureau of Lands.

On June 16, 1999, Candy Maker, Inc. filed an application with the Municipal Trial Court (MTC) of Taytay, Rizal, for the registration of its alleged title over Lots 3138-A and 3138-B under Presidential Decree (P.D.) No. 1529.
The MTC issued orders directing the publication of the notice of the initial hearing, requiring the involvement of multiple agencies (e.g., the Land Registration Authority, the Land Management Bureau, the Forest Management Bureau, and the Community Environment and Natural Resources Officer) to submit reports on the status of the property.

Antonio Cruz, who claimed that his grandparents owned the property, and his family had been cultivating it since 1937.
Fernando Co Siy, the applicant’s treasurer, who confirmed that the property had been peacefully possessed, cultivated, and that realty taxes were regularly paid.

Evidence included tax declarations and testimonies regarding the cultivation and utilization of the land, though the nature of possession was described by some as mere casual cultivation rather than an exclusive and continuous adverse claim.

The Community Environment and Natural Resources Officer (CENRO) reported that the property fell within an alienable and disposable zone under a land classification project.
The Land Registration Authority (LRA) recommended the exclusion of Lot No. 3138-B on account of its status as a legal easement.

Approving a resolution permitting the leasing of untitled shoreland areas under certain conditions.
Presenting survey evidence and a Memorandum alleging that Lot No. 3138-A was located below the prescribed elevation, indicating that part of the property is within the lake’s bed and hence a public land.

The MTC initially set and later rescheduled the date of the initial hearing due to issues with the timely publication of the notice in the Official Gazette and other logistical factors.
On October 12, 2001, the MTC rendered a decision confirming the title over Lots 3138-A and 3138-B in favor of Candy Maker, Inc.
On appeal, the Court of Appeals (CA) on May 21, 2004, affirmed in toto the MTC decision, accepting as evidence the copy of the Official Gazette marked as Exhibit “E-1” and giving weight to evidence of cultivation and tax payments.

Whether the MTC acquired jurisdiction over the registration application due to alleged deficiencies in the publication of the notice (specifically, the absence of actual Official Gazette copies and insufficient evidence regarding publication).
Whether the evidence of possession was adequate to meet the strict requirements of Section 14 of P.D. No. 1529 for establishing exclusive, continuous, public, and adverse possession since June 12, 1945.

The petitioner further argued that survey reports showing the property’s location below 12.50 meters confirmed that the land forms part of the public domain under the regalian doctrine, thus rendering the title non-registerable.

Whether the Municipal Trial Court acquired jurisdiction over Candy Maker, Inc.’s application for registration by relying on a marked copy of the Official Gazette (Exhibit “E-1”) as proof of publication of the notice of the hearing.

Whether the respondent met the legal requirements under Section 14 of P.D. No. 1529, particularly in proving continuous, open, exclusive, and notorious possession dating back to June 12, 1945 or earlier.
Whether the evidence presented—testimonies of cultivation, casual occupation, and tax declarations/tax receipts—sufficiently established a bona fide claim of ownership.

Whether the land in question, given its location below the prescribed elevation and adjacent to Laguna de Bay, qualifies as alienable and disposable or remains within the public domain under the regalian doctrine.
Whether survey reports and government reports establishing its location below 12.50 meters are conclusive evidence that the property is part of the lakebed and hence inalienable.