G.R. No. 213207 - Republic vs. Pasig Rizal Co., Inc.

In 1958, Manuel Dee Ham caused the survey and approval of Plan Psu-169919 over the 944 sqm Subject Property in Barangay Caniogan, Pasig City, and was declared its tax owner.
Manuel died in 1961; his wife (Esperanza) and children inherited the lot and transferred beneficial ownership to Pasig Rizal Co., Inc. (PRCI), which thereafter paid the real property taxes.
On November 6, 2009, Esperanza executed an affidavit formalizing the transfer to PRCI.

In 2010, PRCI, through Esperanza as President, filed an application for original registration under PD 1529, alleging open, continuous, exclusive, and notorious possession since 1956 and lack of encumbrances or adverse claims.
After publication, the only party to enter appearance was the Republic of the Philippines; an order of general default was entered against all others.
PRCI presented ex parte: the approved survey plan, tax declarations and receipts (since 1956), Esperanza’s affidavit, DENR certifications (2011), and neighbor’s affidavit attesting to possession.
On December 1, 2011, the RTC rendered a decision confirming PRCI’s title, finding possession in the concept of an owner for the requisite period and directing issuance of the Decree of Registration.

The Republic, via the OSG, appealed under Rule 41; on February 25, 2014, the CA affirmed the RTC, holding the Subject Property alienable and disposable based on:

A September 15, 2011 DENR FMB Certification of alienability; and
A March 18, 2013 DENR-NCR Certification validating the 2011 Certification under DENR AO 2012-09.

The Republic filed a Rule 45 petition on August 22, 2014, challenging only the proof of land classification status, not possession.
On August 3, 2021, the Court required memoranda and invited the LRA as amicus curiae. PRCI and the Republic filed memoranda on September 13, 2021.
PRCI argued that LC Map 639, plus the 2011 and 2013 DENR certifications, suffice to prove alienability under Malabanan and Spouses Modesto v. Urbina.
The Republic contended that per TAN Properties and Hanover, PRCI needed the DENR Secretary’s approved LC Map certified by the records custodian and live testimony of certifying officials.
Republic Act No. 11573 (effective September 1, 2021) amended PD 1529, shortening the possession requirement to 20 years and prescribing proof of alienability via DENR geodetic engineer certification.

Whether PRCI established its right to registration under PD 1529 by proving acquisitive prescription or possession under existing laws.
Whether PRCI sufficiently proved that the Subject Property is alienable and disposable agricultural land of the public domain, particularly under the requirements of RA 11573.