G.R. No. 152833 - Civil Service Commission vs. Gentallan

Case Summary (G.R. No. 152833)

Key Dates and Procedural Posture

Application for original registration filed by respondent: September 3, 2015.
MCTC Decision granting registration: April 12, 2017.
CA Decision affirming MCTC: March 28, 2019; CA denied reconsideration: July 9, 2019.
Petition for review to the Supreme Court and resolution: Supreme Court granted the petition and reversed the CA, dismissing the land registration case.

Governing Statutes and Legal Points

Primary statutory authority: Presidential Decree No. 1529 (Property Registration Decree), Section 14 (grounds and requisites for original registration). Relevant Civil Code provision: Article 422 (conversion of public dominion property to patrimonial property). Controlling distinctions under jurisprudence between Section 14(1) and Section 14(2) of PD 1529 were applied.

Factual Background — Ownership and Possession Allegations

Respondent alleged fee simple ownership of Lot No. 3394 (5,255 sq. m.) in Brgy. Luta Sur, Malvar, Batangas, acquired from Antonio Aranda by Deed of Absolute Sale dated January 6, 2014. Respondent and its predecessors claimed open, continuous, exclusive, and notorious possession since June 12, 1945 or earlier. Documentary and testimonial evidence offered included a technical description and sepia plan of Lot 3394 (with an annotation regarding classification), tax declarations (oldest on file dated 1955), Land Classification Map No. 3601, DENR Administrative Order No. 97‑37, and testimony of local witnesses including Eliseo Garcia and Antonio Aranda.

Trial Court Proceedings and Evidence

The RTC delegated the hearing to the MCTC. The MCTC issued an order of general default for lack of oppositors and, after taking evidence, granted SPPI’s application by adjudicating and decreeing the parcel in SPPI’s name pursuant to PD 1529. The MCTC relied on documentary proofs (plan, classification maps, CENRO certification, tax declarations) and witness testimony that traced ownership lineage from Segunda Kalaw (sale 1944) through successive transfers to the immediate predecessor and finally to SPPI.

Court of Appeals Ruling

The CA affirmed the MCTC, holding that SPPI had satisfied the requisites of Section 14(1) of PD 1529. The CA rejected the OSG’s contention that Article 422 and the requirements for conversion to patrimonial property applied, noting that Article 422 is implicated when an applicant invokes Section 14(2) (acquisitive prescription) and not Section 14(1). The CA concluded the totality of evidence established continuous, exclusive, and notorious possession since June 12, 1945 or earlier.

Issues Presented to the Supreme Court

Under which provision of Section 14 of PD 1529 (14(1) or 14(2)) should respondent’s application be evaluated?
Whether respondent sufficiently established the requisites for registration under the governing provision.

Legal Standard — Requirements under Section 14(1) and (2)

Section 14(1) requisites (for those in possession under a bona fide claim since June 12, 1945 or earlier): (a) land is alienable and disposable at time of filing; (b) applicant and predecessors have been in open, continuous, exclusive and notorious possession and occupation; and (c) possession under bona fide claim of ownership since June 12, 1945 or earlier.
Section 14(2) requisites (acquisitive prescription): (a) land must be alienable and disposable and patrimonial; (b) possession for at least 10 years in good faith with just title or 30 years regardless of good faith; and (c) the land must have been converted to patrimonial property at the beginning of the prescriptive period, which requires an express governmental manifestation under Article 422 of the Civil Code.

Supreme Court’s Determination of Applicable Provision

The Supreme Court found respondent expressly based its application on Section 14(1) and did not claim acquisition by prescription under Section 14(2). Consequently, Article 422’s requirement of an express government manifestation of patrimonial conversion was inapplicable because petition rested on possession since June 12, 1945 under Section 14(1).

Supreme Court’s Assessment of Evidentiary Sufficiency

The Court concluded SPPI failed to prove the crucial second and third requisites of Section 14(1): open, continuous, exclusive and notorious possession, and possession under a bona fide claim since June 12, 1945. The Court emphasized that proof of specific acts of ownership is required — acts of dominion and control of such character and duration that they amount to ownership in the concept of an owner. Casual or intermittent cultivation and anecdotal childhood recollections (e.g., playing or gathering fruit as a child) do not establish the quality, exclusivity, or duration of possession required.

Key Evidentiary Weaknesses Identified

Earliest tax declarations on record bore the year 1955, which the Court treated as evidence that possession and the claim of ownership may have begun in 1955 rather than by 1945; thus the statutory temporal requirement was not met.
Testimony of an octogenarian witness (Eliseo Garcia), whose recollections concerned events from childhood, was analogous to testimony previously found insufficient in a companion case (G.R. No. 237714). The Court held such testimony, without detailed proof of sustained acts of ownership (e.g., extent and continuity of cultivation, volume of produce, exclusive improvements), amounted to evidence of casual rather than exclusive and notorious possession.

Reliance on Controlling Precedent and Stare Decisis

The Supreme Court applied its decision in Republic v. Science Park of the Philippines, Inc. (G.R. No. 237714, November 12, 2018), which involved the same parties, substantially identical evidence and circumstances, and was decided against SPPI for analogous deficiencies. The Court invoked stare decisis, noting that when facts are substantially the same, like cases should be decided alike. Because the present case was materially indistinguishable from the prior one, the Court declined

Case Syllabus (G.R. No. 152833)

The Case — nature, relief sought, and appellate posture

Petition under the Supreme Court's discretionary appellate jurisdiction seeking reversal of the Court of Appeals' Decision dated March 28, 2019 and its Resolution dated July 9, 2019 in CA-G.R. CV No. 109103 (In Re: Application for Registration of Original Title; Science Park of the Philippines, Inc. v. Republic of the Philippines).
Relief sought: reversal of the Court of Appeals' affirmation of the Municipal Circuit Trial Court (MCTC) of Malvar-Balete, Batangas Decision dated April 12, 2017 in Land Registration Case No. N-138, which granted respondent Science Park of the Philippines, Inc.'s application for original registration of title; and vacation of the denial of reconsideration.
Case decided by the Supreme Court Second Division on June 28, 2021, G.R. No. 248306. Decision authored by Justice Lazaro-Javier; concurrence by Perlas-Bernabe (Chairperson), M. Lopez, Rosario, and J. Lopez JJ.

Procedural history and tribunal delegations

September 3, 2015: Respondent Science Park of the Philippines, Inc. filed an application for original registration of title under Section 14(1) of Presidential Decree No. 1529 (PD 1529) with the Regional Trial Court (RTC) of Tanauan City, Batangas.
September 10, 2015: RTC delegated hearing and disposition of the application to the Municipal Circuit Trial Court (MCTC), Malvar-Balete, pursuant to Administrative Circular No. 6-93-A.
April 26, 2016: MCTC issued an Order of general default because no oppositor allegedly objected to the application.
April 12, 2017: MCTC (Presiding Judge Charito M. Macalintal-Sawali) rendered Decision granting respondent’s application and adjudicating Lot No. 3394, Psc-47, Malvar Cadastre (5,255 sq.m.) in favor of Science Park of the Philippines, Inc. under PD 1529.
Appeal to the Court of Appeals: CA Decision dated March 28, 2019 (Associate Justice Germano Francisco D. Legaspi, with Associate Justices Sesinando E. Villon and Edwin D. Sorongon, concurring) affirmed the MCTC; CA denied reconsideration on July 9, 2019.
Supreme Court: Republic filed petition; Supreme Court granted petition and reversed and set aside the CA Decision and Resolution, and dismissed Land Registration Case No. N-138.

Facts and chain of title asserted by respondent

Subject property: Lot No. 3394, Psc-47, Malvar Cadastre, area 5,255 sq.m., located in Brgy. Luta Sur, Malvar, Batangas.
Respondent’s title acquisition chronology as presented at trial:
- January 29, 1944: Segunda Kalaw sold the land to her sister Micaela Kalaw.
- November 5, 1953: After Micaela’s death, her heirs sold the land to Crisanto Laydia and his wife Agrifina Arcillas through a Kasulatan ng Bilihang Patuluyan ng Lupa.
- June 26, 1996: Antonio A. Aranda purchased the land from Crisanto through a Deed of Absolute Sale.
- January 6, 2014: Respondent purchased the land from Antonio A. Aranda via Deed of Absolute Sale.
Possessory claim asserted: respondent alleged that it, by itself or through predecessors-in-interest, had been in open, continuous, exclusive, and notorious possession of the property since June 12, 1945 or earlier.

Evidence offered by respondent and witnesses

Documentary:
- Technical Description for Lot 3394 (Exhibit marked “L”).
- Sepia copy of Plan, Lot No. 3394, Psc-47, Malvar Cadastre (Exhibit marked “O”), which includes a technical description, boundary sketch, and an annotation indicating the lot is inside alienable and disposable zone per Project No. 39, LC Map No. 3601, certified and annotated with a CENRO certification dated July 21, 2014.
- Land Classification Map No. 3601 (marked Exhibit “II”).
- Tax declarations from the Municipal Assessor’s Office of Malvar; the oldest tax declaration on file presented at trial dated 1955.
Testimonial:
- Testimony of Eliseo Garcia (born June 4, 1933), a lifelong resident of Brgy. Luta Sur: attested knowledge of the property since childhood, proximity to the lot (one kilometer away; three houses from Micaela’s house), play and fruit-gathering on the property from about age seven, recollection that the Kalaws owned several adjoining parcels including Lot No. 3394, that ownership passed from Segunda to Micaela and subsequently to Agrifina Arcillas and Crisanto Laydia, and later to Antonio Aranda who cultivated the land and paid taxes.
- Testimony of Antonio Aranda, immediate predecessor-in-interest, admitting purchase from Crisanto Laydia and sale to respondent (Deed of Absolute Sale dated January 6, 2014), and testifying to cultivation, harvesting, and payment of realty taxes while owner.
Government agency witnesses:
- Representatives from DENR, DENR-CENRO Batangas City, and NAMRIA testified that the property was within the alienable and disposable portion of the public domain based on Land Classification Map No. 3601 and DENR Administrative Order No. 97-37 (issued December 22, 1997 by then Secretary Victor O. Ramos).
- A representative of the Office of Municipal Assessor confirmed sequence of ownership as reflected in tax declarations; earliest tax declaration dated 1955.

MCTC ruling (Decision dated April 12, 2017)

MCTC adjudicated Lot No. 3394, Psc-47, Ap-04-016437 (5,255 sq.m.) in favor of Science Park of the Philippines, Inc., citing PD 1529 (Property Registration Decree).
The trial court found respondent’s evidence sufficient to prove open, continuous, exclusive, and notorious possession and occupation of the parcel classified within the alienable and disposable zone since June 12, 1945 or earlier.
MCTC issuance followed confirmation of Order of General Default.

Court of Appeals review and ruling (Decision dated March 28, 2019)

Court of Appeals affirmed the MCTC and held:
- Article 422 of the New Civil Code was inapplicable because respondent invoked Section 14(1) of PD 1529, not Section 14(2); the express government manifestation required by Article 422 concerns Section 14(2) applications based on acquisitive prescription of patrimonial lands.
- The Court of Appeals found that the totality of respondent’s evidence sufficiently established continuous, exclusive, and notorious possession and occupat