G.R. No. 189970 - Republic vs. Raneses

On March 26, 2007, respondent Crisanto S. Raneses filed an Application for Original Registration of Land Title (LRC No. N-11573-TG) covering two parcels of land identified as Lot No. 3085-A and Lot No. 3085-B in Barangay Napindan, Taguig City, Metro Manila, with a total area of 22,600 square meters.
During the initial hearing on September 24, 2007, respondent presented several documents to comply with the jurisdictional requirements. There was no opposition filed at that stage except that by the petitioner, the Republic of the Philippines.

On October 1, 2007, respondent testified regarding his long possession and occupation of the subject properties, noting that his parents had occupied the land since as early as June 1945.
He narrated that his late father, Pedro Raneses, used to cultivate the land for palay production using modern farming tools, but cultivation ceased upon Pedro’s death in 1982.
Respondent further asserted that his ownership stemmed from an Extrajudicial Settlement of Estate with Deed of Waiver executed on April 24, 1997 by his mother and sisters, wherein they waived their respective rights in favor of him.
Additional documentary evidence included several tax declarations in Pedro’s name, a Conversion-Subdivision Plan prepared by a private geodetic engineer (Engr. Andrew DG. Montallana), and an Inter-Office Memorandum from the Laguna Lake Development Authority (LLDA) detailing field verification findings.

In the absence of opposition from parties other than the petitioner, the Regional Trial Court (RTC) issued an Order of General Default and allowed respondent to present his evidence ex parte.
On October 11, 2007, the RTC rendered its first assailed Order granting respondent’s application for the registration of the subject properties, specifying the areas and lots as titled.
On October 25, 2007, the LLDA formally opposed the application by alleging that the subject properties were located below the reglementary 12.50-meter elevation, thus forming part of the bed of Laguna Lake and qualifying as inalienable public lands.
The RTC, after directing respondent to comment on the LLDA’s Opposition, eventually on November 27, 2007, issued a second Order dismissing the LLDA’s Opposition, giving weight to the respondent’s evidence, particularly the Inter-Office Memorandum which was based on an actual field inspection.

On June 18, 2009, the Court of Appeals (CA) affirmed the RTC’s Orders, ruling in favor of respondent’s application for registration by finding that the subject properties were part of the alienable and disposable lands of the public domain.
Petitioner, represented through the Office of the Solicitor General (OSG), filed a Notice of Appeal (November 7, 2007) and later a Motion for Reconsideration, challenging the adequacy and sufficiency of the evidence presented by the respondent.
Petitioner contended that establishing the alienability and disposability of public lands required incontrovertible evidence, such as a certificate of land classification or a positive act by the government (e.g., reclassification, an executive order, or legislative act), rather than relying solely on a Conversion-Subdivision Plan and the Inter-Office Memorandum.

The crux of the factual dispute centered on whether the subject properties were indeed alienable and disposable or if they, being below the 12.50-meter elevation, remained inalienable public lands as part of the bed of Laguna Lake.
Respondent maintained that the evidence, including the Conversion-Subdivision Plan’s annotation and the Inter-Office Memorandum based on an actual field inspection, sufficiently established the classification of the land.
Petitioner, however, argued that such evidence did not meet the stringent requirements mandated by the law and that the burden of proof rested on respondent to produce incontrovertible evidence to overcome the presumption of inalienability under the Regalian Doctrine.

Respondent based his claim to registration on Section 14(1) of Presidential Decree No. 1529 (Property Registration Decree) and Section 48(b) of Commonwealth Act No. 141 (Public Land Act), which authorize registration upon satisfying requirements such as open, continuous, exclusive, and notorious possession since June 12, 1945.
Petitioner invoked the Regalian Doctrine as encapsulated in Section 2, Article XII of the 1987 Constitution, which provides that all lands of the public domain are owned by the State unless a positive act is undertaken to alienate or reclassify them.

Whether respondent Crisanto S. Raneses has met the burden to prove by incontrovertible evidence that the subject properties are alienable and disposable lands of the public domain.

Did the documents presented—the Conversion-Subdivision Plan and the Inter-Office Memorandum—satisfy the evidentiary requirements under Section 14(1) of P.D. No. 1529?
Whether the absence of a certificate of land classification or a corresponding positive governmental act undermines the claim to registration.

Whether the proper weight should be accorded to the Inter-Office Memorandum based on an actual field inspection as opposed to the criticisms raised regarding the ECD Memorandum and other evidentiary submissions.

Should the actual field verification findings override the prima facie evidence of the land being below the reglementary elevation?
How does this evaluation impact the presumption under the Regalian Doctrine that favors inalienability of public lands unless definitively altered by government action?