G.R. No. 210738 - Republic vs. Spouses Alonso

The petitioner is the Republic of the Philippines, represented by the Office of the Solicitor General (OSG).
The respondents are spouses Guillermo Alonso and Inocencia Britanico-Alonso.
The case involves a petition for registration of Lot 2209, Cad. 24, Iloilo Cadastre, AP-06-005399, a lot situated in Poblacion, Oton, Iloilo, with an approximate area of 724 square meters.

The respondents filed the petition asserting that the subject land, an alienable and disposable property of the public domain, had been owned and possessed by their predecessors-in-interest (spouses Rafael C. Montalvo and Manuela Garnica) since 1945.
They further claimed that through an extrajudicial settlement among heirs (with waiver of hereditary shares) followed by a Deed of Sale dated January 27, 1998, the property was legally transferred to their names.
The respondents contended that by “tacking” their possession onto that of their antecedents, their long, open, continuous, exclusive, and notorious possession under a bona fide claim of ownership since time immemorial warranted registration in their favor.

The Regional Trial Court (RTC) of Iloilo City, Branch 22, dismissed the respondents’ petition on December 29, 2009, holding that they failed to prove that the possession by them and their predecessors-in-interest was open, continuous, exclusive, and notorious since time immemorial or earlier than 1945.
A Motion for Reconsideration filed by the respondents was denied by the RTC on April 26, 2010.
The respondents elevated the case to the Court of Appeals (CA), insisting that the required possession elements had been sufficiently proven, and the CA, in its Decision dated May 31, 2013, reversed the RTC ruling by granting the registration of the subject land in their names.

Aside from the possession claim, the Republic, through the OSG, argued that even if possession were established, it was not proven that the land was alienable and disposable.
The Republic contended that the respondents failed to demonstrate the mandatory element of a positive act by the Executive Department (e.g., a certification from the Community Environment and Natural Resources Office [CENRO] or the Provincial Environment and Natural Resources Office [PENRO] and an approved classification by the DENR Secretary) required to establish that the property is part of the alienable and disposable lands of the public domain.
Evidence such as testimony from Henry Belmones, the Chief of the Land Evaluation Party of the DENR, was found deficient as the supporting documents (like the Control Map No. 18 and a corresponding survey plan) were not properly offered or authenticated.

Presidential Decree No. 1529, Section 14, explicitly requires that for the registration of title, the applicant and their predecessors must have occupied an alienable and disposable land under a bona fide claim of ownership since June 12, 1945, or earlier.
To satisfy the “alienable and disposable” element, applicants typically must submit:

A certification from the CENRO or PENRO confirming the land’s classification, and
A copy of the original classification approved by the DENR Secretary, certified as a true copy by the legal custodian of official records.

In the present case, the respondents did not submit such certification and classified documentation, thereby weakening their claim even if the possession requirement was met.

After the CA Decision and the Republic’s unsuccessful motion for reconsideration against it (Resolution dated December 12, 2013), the Republic filed a Petition for Review on Certiorari before the Supreme Court.
The central factual dispute thus revolves around both the sufficiency of the possession claim and the failure to prove that the subject land is alienable and disposable, which is essential for the registration process.

Whether the registration of Lot 2209, Cad. 24, Iloilo Cadastre, is proper considering the competing claims.
Whether the respondents’ demonstration of open, continuous, exclusive, and notorious possession—from time immemorial or at least since 1945—is sufficient for registration.
Whether the respondents have met the statutory requirement of proving that the land is alienable and disposable through a positive act from the Executive Department (i.e., the requisite certifications and classification documents).
Whether the failure to produce the necessary CENRO/PENRO certification and DENR Secretary-approved classification renders the claims of possession ineffective in overcoming the presumption of State ownership over public domain lands.