G.R. No. 170757 - Valiao vs. Republic

On August 11, 1987, petitioners Pacifico M. Valiao and his co-heirs Lodovico, Ricardo, Bienvenido (all surnamed Valiao), and Nemesio M. Grandea filed an application for registration of title over a 504,535 square meter parcel of land situated in Barrio Galicia, Municipality of Ilog, Negros Occidental.
The application was filed with the Regional Trial Court (RTC) of Kabankalan, Negros Occidental, Branch 61, categorized as Land Registration Case No. 03.

On June 20, 1988, private oppositors Macario Zafra and Manuel Yusay moved to dismiss the application, arguing:

The Republic of the Philippines, through the Office of the Solicitor General (OSG), opposed the application on August 24, 1988, asserting:

Petitioners and their predecessors did not possess the land in open, continuous, exclusive, and notorious possession since June 12, 1945 or earlier.
Documents offered did not constitute sufficient evidence of bona fide acquisition or possession.
The land was part of the public domain and thus inalienable.
The case was barred by a prior final judgment in a cadastral case involving the same parties and subject matter.

The RTC denied the motion to dismiss filed by private oppositors on July 3, 1989, and proceeded with trial.
Petitioners claimed acquisition of the land in 1947 through their uncle Basilio Millarez, who allegedly purchased it in 1916 via a handwritten Spanish deed from Fermin Payogao. Basilio possessed the land until his death in 1947; thereafter, petitioners possessed it until 1966 when they were dispossessed by Macario Zafra.
Petitioners supported their claim with Tax Declaration No. 9562 dated September 29, 1976, under Basilio’s heirs’ names.
On December 15, 1995, the RTC granted the petitioners’ application for registration, declaring them as true owners, except Lodovico who sold his right to Zafra. The RTC recognized the fishpond permits of oppositors but ruled in favor of petitioners' title.

Aggrieved, the private oppositors and the Republic appealed.
The Court of Appeals (CA), in its Decision dated June 23, 2005, reversed the RTC ruling. It held that:

Classification of public lands is exclusively an executive prerogative, and absent such classification the land remains unclassified and inalienable.
A previous cadastral case involving the same parties and lot held that Lot No. 2372 belongs to the Republic, which barring relitigation under res judicata applies.
Petitioners failed to prove possession since June 12, 1945 or earlier under the conditions required by law.
The subject land is inalienable public domain and cannot be acquired or registered by prescription.

The CA denied petitioners’ registration application, declared claims of private oppositors moot, and confirmed the land as inalienable public domain.
Petitioners' motion for reconsideration was denied by the CA on November 17, 2005.

Petitioners filed a petition for review on certiorari under Rule 45 of the Rules of Court to set aside the CA decision and resolution.
The petition raised issues on the alienability of the land, prescription claims, application of res judicata, and sufficiency of possession evidence.

Whether Lot No. 2372 is alienable and disposable land of the public domain.
Whether prescription can be claimed over Lot No. 2372 by the petitioners.
Whether the prior decision of the Court of Appeals in a previous cadastral case involving the same parties and lot operates as res judicata in barring the present registration application.
Whether the alleged possession by petitioners and their predecessors-in-interest is sufficient to sustain their claim for prescription and registration.