G.R. No. 209462 - Ususan Development Corp. vs. Republic

The subject matter is a 3,975 square meter parcel of land (Psu-244418) located at Pusawan, Barangay Ususan, Taguig City.
Originally owned by Jose Carlos during his lifetime, the property was later inherited by his daughter, Maria Carlos, upon his death in 1948.
Maria Carlos formalized her claim by declaring the land in her name for taxation purposes and ensuring payment of the realty taxes.
In 1968, Maria Carlos initiated the survey of the lot under a conversion plan, which subsequently received approval from the Bureau of Lands on December 9, 1970.

On October 16, 1996, Maria Carlos sold the subject lot to Ususan Development Corporation, which later became DMCI Project Developers, Inc.
Subsequently, the buyer sought to formalize its ownership by filing an application for registration and confirmation of title before the Regional Trial Court (RTC), asserting that:

The subject lot is part of the alienable and disposable (AnD) lands of the public domain, as evidenced by a Certification dated June 6, 2007, issued by Ali Bari of the RTD-FMS-DENR.
The Taguig City Land Registration Case Map No. 2623, approved on January 3, 1968, further corroborated the property’s classification, a matter also validated by a Supreme Court Decision dated August 31, 2005, in a registration suit filed by Maria Carlos.

The applicant emphasized that the land, now designated as industrial, was neither within any military or naval reservations, nor subject to existing claims, encumbrances, or mortgages.
The chain of possession alleged included open, exclusive, continuous, and notorious occupation from June 12, 1945, by petitioner's predecessors-in-interest.
Testimonies were presented by Teresita Victoria (daughter of Maria Carlos) and former adjacent owner Pilar Guillermo to establish:

The long-standing, peaceful, and uninterrupted possession of the subject lot by the Carlos family.
Community acknowledgment of such possession and usage of the land for agricultural and animal husbandry purposes.

Granted the application for registration and confirmation of title.
Declared Ususan Development Corporation (now DMCI Project Developers, Inc.) as the owner in fee simple of the parcel.

The Republic of the Philippines, through the Office of the Solicitor General, opposed the registration application on the basis that:

The subject property remained part of the public domain and was not eligible for private ownership.
The Certification from the RTD-FMS-DENR was not sufficient to prove that the land was classified as AnD lands since only the Community and Provincial Environment and Natural Resources Offices, subject to the DENR Secretary’s approval, were competent to issue such certifications.
Neither petitioner's possession nor that of its predecessors-in-interest met the legal requirements for registration under the provisions of PD 1529.

The Court of Appeals (CA) reversed the RTC Decision on March 12, 2013, and dismissed the application for lack of merit.
A Motion for Reconsideration filed by petitioner before the CA on October 1, 2013, was similarly denied, prompting the present Petition for Review on Certiorari.

Whether the Court of Appeals committed an error of law in reversing the RTC Decision that granted the application for registration and confirmation of title of the subject lot.
Whether the evidence, particularly the three documents (CENRO/PENRO certification, certified true copy of the original classification approved by the DENR Secretary, and certified true copy of the approved Land Classification Maps), satisfies the requirements for proving that the subject lot is within the alienable and disposable lands of the public domain.