G.R. No. 179990 - Republic vs. Gielczyk

On July 17, 1995, Diosdada I. Gielczyk (respondent) filed an application for original registration of ownership under Land Registration Commission (LRC) Case No. N-452 for two parcels of land, Lot Nos. 3135-A and 3136-A, situated in Jugan, Consolacion, Cebu.
The respondent claimed ownership based on purchase from Constancio and Luisa Ceniza, presented approved plans and technical descriptions of the lots, tax declarations dating back to 1948, deeds of absolute sale, certifications from DENR and CENRO attesting to alienability and absence of public land application, and established possession and payment of taxes for over 30 years.
The lots were described in detail with precise technical boundaries, survey details, and area:

No open, continuous, exclusive, and notorious possession of the land since June 12, 1945, or earlier, by respondent or her predecessors-in-interest.
The tax declarations and other muniments submitted were insufficient to prove bona fide claim or possession and were of recent vintage.
Failed to file application within the six-month prescription period required by P.D. No. 892.
The land applied for remained public domain and not subject to private appropriation.

The Regional Trial Court (RTC), Mandaue City Branch 56, ruled in favor of the respondent, confirming her registrable title and directing issuance of original certificate of title.
The petitioner appealed to the Court of Appeals (CA) which affirmed the RTC decision on September 21, 2007, reasoning that the registration was proper under Section 14(2) of P.D. No. 1529 based on ownership acquired by prescription.
The CA emphasized proof of possession through tax declarations indicating continuous and notorious possession in the concept of an owner for over 40 years.
The petitioner filed a Petition for Review before the Supreme Court, challenging the CA ruling on the grounds that the petitioner did not prove the lands were alienable and disposable public lands nor completed the required 30-year possession period under the law.
The respondent did not file a comment despite notification.

Whether the Court of Appeals erred in upholding the trial court’s decision granting registration based mainly on tax declarations without establishing an expressed State declaration of alienability and disposal of the public land, and without sufficient proof that the respondent and predecessors-in-interest met the necessary legal requirements of possession and ownership under P.D. No. 1529.