G.R. No. 156132 - Citibank, N.A. vs. Sabeniano

Sogod Development Corporation filed an application for the registration and confirmation of title over Lot No. 2533, Cadastre 827-D, situated in Barangay Tabunok, Sogod, Cebu, covering an area of 23,896 square meters.
The application was filed on December 9, 1999, under Land Registration Case No. 016-SO, asserting that the land had been in open, continuous, exclusive, and notorious possession since June 12, 1945, or earlier.
Sogod claimed to have purchased the land from Catalina Rivera per a deed of absolute sale dated October 28, 1996, and supported its claim with both documentary evidence and witness testimonies.

Sogod and its predecessors-in-interest demonstrated possession through a series of tax declarations, including one from 1945, evidencing the land’s continuous agricultural use.
Witness testimonies—particularly those of Celedonio Campos, Jr., Bonifacia Sugarol, and Ranito Quadra—attested to the chain of possession whereby the land was originally held by Ignacia Rivera, inherited by Catalina Rivera, and subsequently acquired by Sogod.
Documentary evidence also included a tax clearance issued on July 30, 1999, which confirmed the payment of all taxes over the land, and a subsequent tax declaration issued in Sogod’s name.

On May 10, 2001, the Municipal Circuit Trial Court of Catmon-Carmen-Sogod granted Sogod’s application for original registration of title.
The Court of Appeals subsequently affirmed this decision on August 25, 2005, and later denied the Motion for Reconsideration on November 7, 2006.
A Petition for Review on Certiorari was filed, challenging the lower courts’ findings and raising constitutional and evidentiary issues.

Sogod failed to prove open, continuous, exclusive, and notorious possession dating back to or before June 12, 1945.
The possession seemingly began only after the land was declared alienable and disposable in 1986, thereby excluding earlier, unclassified possession on forest land.
Article XII, Section 3 of the 1987 Constitution disqualifies private corporations from applying for original registration of title to alienable lands.
The tax declarations presented were too recent or ambiguous to establish actual possession since the required fixed date.

The land was alienable and disposable at the time of the application (1999), regardless of its earlier classification.
It had established possession since June 12, 1945, supported by both tax declarations—including the crucial 1945 declaration—and witness testimony regarding continuous agricultural utilization.
The evidentiary record sufficiently demonstrated that possession was exercised under a bona fide claim of ownership.

Whether possession and occupation of the land prior to its formal classification as alienable and disposable (i.e., when it was still forest land) should count toward the required period beginning June 12, 1945.
Whether the conversion of the land into an alienable and disposable status is necessary for the entire duration of possession, or only at the time of the application.

Whether the documentary evidence—including tax declarations and a tax clearance—and witness testimonies established open, continuous, exclusive, and notorious possession under a bona fide claim of ownership since the fixed date.
Whether the presentation of a tax declaration from 1945, despite gaps due to destruction of pre-war records, satisfies the evidentiary requirements for establishing possession.

Whether Article XII, Section 3 of the 1987 Constitution disqualifies private corporations from applying for original registration of title to alienable lands.
Whether the purported errors in the lower courts’ acceptance of evidence based on recent tax declarations negatively affect the propriety of the registration.

Whether Section 48(b) of the Public Land Act, as amended, should be read to require that the land must have been alienable and disposable throughout the period of possession or only when the application is made.
Whether the legislative intent in fixing the date of June 12, 1945 was to ensure that continuous possession, regardless of prior land classification, would convert public land into private ownership by operation of law.