G.R. No. 172011 - Republic vs. Rizalvo, Jr.

Respondent Teodoro P. Rizalvo, Jr. filed an application on December 7, 2000, before the Municipal Trial Court (MTC) of Bauang, La Union, for the registration of an 8,957-square meter parcel of land located in Brgy. Taberna, Bauang, La Union.
The land was identified by Survey Plan PSU-200706 and was claimed to be acquired by the respondent through a Deed of Transfer dated December 31, 1962.

The Deed of Transfer demonstrating the acquisition from his mother, Bibiana P. Rizalvo.
A photocopy of the Deed of Absolute Sale dated July 8, 1958 (notably referred to with slight discrepancies in some records) involving the transfer from Eufrecina Navarro to Bibiana P. Rizalvo.
Tax Declarations (e.g., Tax Declaration No. 22206 for 1994 and Tax Declaration No. 11078 for 1948) and a bundle of official receipts evidencing payment of real property taxes from 1952 up to the filing of the application.

Respondent testified that he was in adverse, open, exclusive, and notorious possession of the property, including the installation of concrete markers during the survey and active payment of taxes.
His mother, Bibiana P. Rizalvo, testified that she had purchased the property from Eufrecina Navarro and had enjoyed unchallenged ownership and occupation, along with bearing the responsibility of paying real property taxes and improving the lot.

Land Investigator/Inspector Dionisio L. Picar of the Community Environment and Natural Resources Office (CENRO) issued a report on July 17, 2001.
The report confirmed that the parcel lies within the alienable and disposable zone and noted actual occupation and possession by the applicant.

The Office of the Solicitor General (OSG) opposed the registration by filing its Opposition on April 20, 2001.

OSG argued that neither the respondent nor his predecessors-in-interest were in the required open, continuous, exclusive, and notorious possession since June 12, 1945.
The OSG maintained that the tax declarations and receipts failed to establish competent and sufficient evidence of ownership.
Additionally, OSG contended that the subject property remained part of the public domain and was not properly alienated for private acquisition.

With no private oppositor coming forward, the trial court issued an Order of Special Default (except against the Republic) and eventually rendered its Decision on November 29, 2001, approving the registration of the land.

The Republic, represented by the OSG, filed a Notice of Appeal on December 21, 2001.
The Court of Appeals (CA) affirmed the MTC’s ruling on March 14, 2006, thereby supporting the registration of the property.
Subsequently, the OSG elevated the case to the Supreme Court via a petition for review on certiorari under Rule 45 of the 1997 Revised Rules of Civil Procedure, challenging the sufficiency and legality of the approval.

Whether the respondent and his predecessors-in-interest have established the requisite open, continuous, exclusive, and notorious possession and occupation of the subject property since June 12, 1945, as mandated by Section 14 of Presidential Decree No. 1529.
Whether the documentary and testimonial evidence offered by the respondent, particularly the possession evidence beginning from 1948, satisfies the statutory requirement for acquiring an imperfect title over alienable and disposable public lands.
Whether the thirty (30)-year prescriptive period for acquiring ownership by prescription can be applied, given the timing of the land’s certification as alienable and disposable (1987) relative to the filing of the application (2000), and in the absence of an express declaration by the State withdrawing the land from public use.