G.R. No. 164408 - Republic vs. Zurbaran Realty and Development Corporation

The respondent, Zurbaran Realty and Development Corporation, filed an application for original registration of a 1,520 square meter parcel of land in Barrio Banlic, Cabuyao, Laguna.
The land is identified as Lot 8017-A of Subdivision Plan CSD-04-006985-D, also recorded as part of Lot 8017 under the Cabuyao Cadastre with Cad. No. 455-D.
It was acquired by the respondent on March 9, 1992 from Jane de Castro Abalos, and was supported by documents such as the deed of sale, technical description, tracing cloth plan, and tax declarations.

Gloria P. Noel, Vice President and Treasurer of the respondent, who testified regarding the purchase, possession, continuous occupation, and improvement of the property.
Engr. Edilberto Tamis, who attested his familiarity with the land’s history and sale transactions.
Armando Espela, a retired land overseer, who detailed the continuous, open, and adverse possession of the land by the Hemedez family and its successors, emphasizing the historical occupation and transformation of the land from agricultural use.

A status report was requested from the Land Management Bureau, the Community Environment and Natural Resources Office (CENRO) of Los Baños, Laguna, and other associated bureaus.
CENRO and its inspectors confirmed the land was within the alienable and disposable area under Land Classification Project No. 23-A of Cabuyao, as certified in Forest Management documents.

The existence of physical boundaries (such as a concrete fence) and constructed improvements.
The land had been acquired through sale prior to the filing, and possession was continuous, open, and peaceful.
No adverse claims, liens, or mortgages affected the land.
Tax records showed initial declaration in 1960 and subsequent updated tax declaration in the name of the respondent, with real property taxes paid continuously since 1968.

In the Regional Trial Court (RTC) in San Pedro, Laguna, the respondent’s application was scrutinized regarding the open, continuous, exclusive, and adverse possession and occupation of the land.
On May 12, 1997, the RTC rendered a decision affirming that the respondent and its predecessors had possessed the land under a bona fide claim of ownership, even prior to 1960, and consequently granted the application.
The RTC order mandated the confirmation and registration of title in the respondent’s name and provided for the issuance of a decree of title upon the decision becoming final.

The Republic, represented by the Director of Lands, opposed the application, alleging:

The respondent’s and its predecessors’ possession did not comply with the statutory requirement of possessing the land since June 12, 1945, or earlier.
There was no competent evidence establishing the exact time when the land was declared alienable and disposable.
The land, being part of the public domain, had not been expressly converted into patrimonial property, rendering it not susceptible to private appropriation via acquisitive prescription.

The Court of Appeals (CA) affirmed the RTC’s decision on June 10, 2004, relying on the corroborative evidence of government reports and witness testimonies that supported the existence of long-term, continuous, and adverse possession.

Whether the respondent’s application for original registration filed under Section 14(2) of Presidential Decree No. 1529 established all the required requisites, particularly:

The possession and occupation of the land under a bona fide claim of ownership.
Compliance with the statutory period of possession required for acquisitive prescription, considering the necessary conversion of the land into patrimonial property of the State.

Whether the evidence presented was sufficient to show that the land was declared alienable and disposable prior to the period required by law, and whether it had been expressly converted into patrimonial property at the onset of the possession period.