Case Summary (G.R. No. 108998)
Key Dates
June 17, 1978 – Purchase of Lots 347 and 348 in San Pablo City
February 5, 1987 – Application for Torrens registration filed
August 24, 1994 – En Banc decision
Applicable Law
1987 Constitution, Art. XII, §§ 7–8 (transfer of private lands; former natural-born citizens)
BP 185 (privilege for former Filipino citizens to acquire private residence lands)
Public Land Act (CA 141), as amended by PD 1073 (tacking of predecessor’s possession since June 12, 1945)
Property Registration Decree (PD 1529) – Torrens system confirms existing titles
Facts
– In 1978, as Filipino citizens, spouses Lapina and de Vega bought two parcels (total 91.77 sq m.) from Cristeta Dazo Belen.
– Their predecessors had occupied the lots openly, continuously, exclusively, and notoriously since at least 1937.
– By 1987, both spouses had naturalized as Canadian citizens and sought judicial confirmation of their Torrens titles.
– The Republic opposed, contending that (a) the lots remained public until court confirmation, (b) respondents lacked 30-year possession since 1945, and (c) foreign nationals cannot register private land.
Procedural History
– Regional Trial Court approved registration, finding valid tacking of predecessor’s 30-year possession and noting Torrens as confirmation, not acquisition, of title.
– Court of Appeals affirmed, emphasizing respondents’ Filipino citizenship at acquisition and uninterrupted possession under CA 141 and PD 1073.
– Republic filed a belated petition for review before the Supreme Court.
Issue
Can former natural-born Filipinos, now foreign nationals, secure Torrens registration of private land they acquired as Filipinos and whose predecessors possessed the land for the requisite statutory period?
Supreme Court’s Analysis
Torrens System as Confirmation, Not Acquisition
– Ownership vests by operation of law upon completion of statutory possession (Public Land Act, § 48[b], as amended).
– Judicial registration merely confirms an already vested title (Municipality of Victorias v. CA; Director of Lands v. IAC).Tacking of Predecessor’s Possession
– Respondents’ predecessors occupied alienable and disposable public land since 1937, satisfying the continuous-possession requirement dating from June 12, 1945 (PD 1073).
– The spouses stepped into their predecessors’ shoes, inheriting the perfected possessory rights.Private Character of the Land
– By operation of law, the land ceased to be public domain upon completion of the 30-year possession, becoming private property beyond the Director of Lands’ disposal authority.Constitutional and Statutory Right of Former Natural-Born Citizens
– Art. XII, § 8 of the 1987 Constitution permits a natural-born Filipino who lost citizenship to be a transferee of private land, subject to legislative limitations.
– BP 185 implements that privilege by providing residence-use acquisition up to 1,000 sq m. (urban) or 1 ha
Case Syllabus (G.R. No. 108998)
Facts
- On June 17, 1978, spouses Mario B. Lapina and Flor de Vega, then natural-born Filipino citizens, bought Lots 347 and 348, Cad. s38-D (91.77 sq. m.) in San Pablo City from Cristeta Dazo Belen.
- On February 5, 1987, after both had been naturalized as Canadian citizens, they filed an application for registration of title over the two parcels before the Regional Trial Court (RTC) of San Pablo City, Branch XXXI.
- The Republic opposed the registration, invoking the constitutional prohibition on aliens acquiring private land and various technical objections regarding possession and classification.
Procedural History
- RTC of San Pablo City granted the spouses’ application, confirming their title and directing issuance of a certificate of title with an easement annotation.
- On appeal, the Court of Appeals (CA) affirmed, holding that the spouses acquired ownership in 1978 while still Filipino citizens and that Torrens registration is merely confirmatory.
- The Republic filed a petition for review before the Supreme Court, raising constitutional issues despite the petition being belated.
Issue
- Whether a natural-born Filipino who has lost Philippine citizenship may apply for Torrens registration of private land acquired by purchase while still a citizen, when the land was already alienable and disposable public domain confirmed by thirty-year possession under the Public Land Act.
Trial Court Ruling
- Found applicants and their predecessors-in-interest in open, continuous, exclusive, notorious possession under bona fide claim since before June 12, 1945.
- Concluded all requirements of Presidential Decree No. 1529 (Property Registration Decree) and Public Land Act had been satisfied.
- Approved the application and directed issuance of the certificate of registration.