Facts:

The case involves a Petition for Review on Certiorari filed by the Republic of the Philippines against respondents Apostolita San Mateo, Brigida Tapang, Rosita Accion, and Celso Mercado. The petition was filed to contest the Decision of the Court of Appeals (CA) dated September 14, 2012, which upheld the Regional Trial Court (RTC) ruling from November 3, 2010, in LRC Case No. N-11398. The RTC had ordered the registration of a 12,896 square-meter parcel of land located in Ibayo, Napindan, Taguig City, described as Lot 3226, MCadm 590-D, in the names of the respondents. The respondents claimed that the land was inherited from their grandfather, Leocadio Landrito, who had occupied a portion of it since 1948, as evidenced by Tax Declaration No. 3659. After Leocadio's death, his children inherited the property, and subsequent waivers of rights were executed by the widows of two of his children in favor of the respondents. The petition for registration included various document...

Facts:

Background of the Case
The case originated from a Petition for Registration of Title filed on January 27, 1999, by respondents Apostolita San Mateo, Brigida Tapang, Rosita Accion, and Celso Mercado before the Regional Trial Court (RTC) of Pasig City, Branch 127. The subject of the petition was a 12,896 square-meter parcel of land located in Ibayo, Napindan, Taguig City, described as Lot 3226, MCadm 590-D of the Conversion Plan AS-00-000233.

Ownership and Possession Claims
Respondents claimed that the land was originally owned by their grandfather, Leocadio Landrito, who had been in possession of a 5,500 square-meter portion since 1948, as evidenced by Tax Declaration (TD) No. 3659. Upon Leocadio’s death, the property was inherited by his three children: Crisanta, Amador, and Juanito. Amador and Juanito later mortgaged their shares to Crisanta and her husband, but they failed to settle their obligations. Consequently, the widows of Amador and Juanito executed waivers of rights in favor of the respondents, who are the heirs of Crisanta.

Supporting Documents
Respondents submitted the following documents to support their petition:

• Original tracing cloth plan AS-00-000233, blueprints, and technical description of the land.
• Surveyor’s certificate.
• Deed of extra-judicial settlement of Leocadio’s estate.
• Various tax declarations and tax receipts.

Oppositions to the Petition
Several parties opposed the petition:

1. Globe Steel Corporation (GSC): Claimed that the application might encroach on its adjoining properties.
2. New Donavel Compound Neighborhood Association, Inc. (NDCNAI): Argued that it had a better right of possession, as its members were the actual occupants of the lot.
3. Laguna Lake Development Authority (LLDA): Contended that the lot is below the reglementary lake elevation of 12.50 meters, making it part of the Laguna Lake bed and thus inalienable public land.

LRA Report
On July 25, 2008, the Land Registration Authority (LRA) adjusted the area of the property to 12,776 square meters to rectify a discrepancy in the technical description.

RTC Decision
On November 3, 2010, the RTC granted the petition for registration, ruling that:

• Respondents and their predecessors had been in open, continuous, and exclusive possession of the lot since 1948.
• The lot is alienable and disposable, as evidenced by certifications from the DENR-South CENRO and LLDA.

CA Decision
The Court of Appeals (CA) affirmed the RTC’s decision on September 14, 2012, rejecting the Republic’s arguments regarding jurisdiction, possession, and alienability.

Issue:

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Ruling:

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Ratio:

1. Jurisdiction in Land Registration Cases: In actions in rem, such as land registration cases, publication of the notice of initial hearing is sufficient to confer jurisdiction on the court. Personal notice to all claimants is not required.

2. Proof of Alienability: To prove that a property is alienable and disposable, the applicant must present:

   • A CENRO or PENRO certification stating that the land is alienable.
   • A certified true copy of the DENR Secretary’s original classification approving the land as alienable and disposable.
     Mere reliance on a CENRO certification, without proof of the DENR Secretary’s approval, is insufficient.

3. Possession and Tax Declarations: Tax declarations, while not conclusive proof of ownership, are good indicia of possession in the concept of an owner.

4. Pro Hac Vice Rule: The Court clarified that the pro hac vice rule in Republic v. Vega applies only to cases decided before the strict compliance rule in T.A.N. Properties was established. In this case, since the RTC decision was rendered after T.A.N. Properties, strict compliance was required, and respondents failed to meet this standard.

Conclusion:

The Supreme Court denied the respondents’ application for registration of title, emphasizing the need for strict compliance with the requirements for proving alienability and disposability of public land. The absence of proof of the DENR Secretary’s approval of the CENRO certification was fatal to the respondents’ claim.