G.R. No. 185603 - Republic vs. Local Superior of the Institute of the Sisters of the Sacred Heart of Jesus of Ragusa

The case involves a petition for review on certiorari filed by the Republic of the Philippines (petitioner) against the Local Superior of the Institute of the Sisters of the Sacred Heart of Jesus of Ragusa (respondent).
The petition seeks the reversal of a Court of Appeals decision that affirmed the trial court’s decision granting registration of title in the respondent’s name.
The underlying controversy involves an application for registration of title based on Section 14(1) of Presidential Decree No. 1529 (the Property Registration Decree).

The respondent asserts that the subject property was acquired by purchase on September 19, 2005, and that it has been in continuous, uninterrupted, open, and public possession in the concept of an owner since that time.
It is further alleged that the respondent’s predecessors-in-interest had been in similar possession as early as 1940, with some evidence—such as witness testimony—indicating possession even earlier (as far back as 1943).
The possession history is supported by documentary evidence that includes Deeds of Sale, tax declarations (commencing in 1948), continuous payment of realty taxes, and recorded improvements on the property.
A key witness, Romulo Gonzales, testified regarding his early awareness of the property through his grandfather, Andres Velando, noting that possession and improvements had been evident from an early age.

The respondent filed its Application for Registration under Section 14(1) of PD No. 1529, which requires that the applicant, or its predecessors-in-interest, have been in open, continuous, exclusive, and notorious possession under a bona fide claim of ownership since June 12, 1945, or earlier.
In support of this, the respondent argued that the combined period of possession by its predecessors-in-interest and itself totals fifty-seven (57) years.
The application was set for hearing after the trial court found that all jurisdictional requirements had been complied with and that the adjoining lot owners had been properly identified.
The trial court granted the application for registration, which was subsequently affirmed by the Court of Appeals (CA).

The petitioner, represented by the Office of the Solicitor General, opposed the registration on several grounds, including:

The allegation that neither the respondent nor its predecessors-in-interest had been in the requisite open, continuous, exclusive, and notorious possession for not less than thirty years.
The contention that the tax declarations and tax payments, being of recent vintage, did not serve as credible muniments of title.
The argument that the claim in fee simple on the basis of a Spanish title or grant was no longer viable due to a failure to timely file the application for registration as required by P.D. No. 892.
The claim that the land in question is a portion of the public domain of the petitioner, thereby not subject to private appropriation.

The respondent submitted a certification from the DENR Community Environment and Natural Resources Officer (CENRO) attesting that the land was within an area declared alienable and disposable.
The CA’s decision, however, referenced prior Supreme Court jurisprudence (e.g., Republic of the Philippines v. T.A.N. Properties, Inc.) holding that such certification is insufficient unless accompanied by proof that the DENR Secretary approved the land’s classification as alienable and disposable through formal documentation.

After the trial court’s decision favoring the respondent, the petitioner appealed to the Court of Appeals.
The CA affirmed the decision primarily on the basis of the credible testimony (particularly that of Gonzales) and the documentary evidence showing possession, while also addressing the issue of possession period and the proper interpretation of Section 14(1) of PD No. 1529.
The CA acknowledged that while possession requirements were met, further proof was necessary to conclusively demonstrate that the property was alienable and disposable at the time of application.

Whether the CA seriously erred in ruling that the respondent’s period of possession was sufficient to warrant registration of title in its name.

Does possession established prior to the declaration of alienability (i.e., before March 15, 1982) count towards the statutory requirement under Section 14(1) of PD No. 1529?
Whether the combined evidence (tax declarations, continuous payment of taxes, and witness testimony) sufficiently established open, continuous, exclusive, and notorious possession from as early as 1943/1945.
Whether the evidence provided, particularly the DENR-CENRO certification, adequately proved that the property was alienable and disposable at the time the application for registration was made.