Case Summary (G.R. No. 248306)
MCTC Decision
By Decision dated April 12, 2017, the MCTC granted registration, finding that respondent and its predecessors-in-interest had established open, continuous, exclusive, and notorious possession and occupation of alienable and disposable public domain land since June 12, 1945 or earlier, in accordance with PD 1529, Section 14(1). The court ordered issuance of a declared title in respondent’s favour.
Court of Appeals Ruling
On petition by the OSG, the CA, in its March 28, 2019 Decision, affirmed the MCTC. It rejected the OSG’s reliance on Article 422 of the Civil Code—applicable only under Section 14(2) for acquisitive prescription—and held that respondent sufficiently proved the three requisites under Section 14(1): (1) alienable and disposable character of the land (via DENR and NAMRIA certifications); (2) continuous, exclusive, open, and notorious possession (via Eliseo Garcia’s testimony and historical tax declarations); and (3) possession under a bona fide claim of ownership since June 12, 1945 or earlier. Reconsideration was denied on July 9, 2019.
Petition for Review and Issues
The Republic filed a Rule 45 petition seeking reversal of the CA, arguing that respondent failed to establish possession and occupation since June 12, 1945 (earliest tax declaration dated only 1955; witness testimony described casual childhood play and fruit gathering, insufficient to prove acts of dominion) and, under Section 14(2), lacked proof of an express government declaration converting the land to patrimonial status as required by Article 422.
Legal Framework under PD 1529
Section 14(1) allows registration for those who, by themselves or through predecessors-in-interest, have maintained open, continuous, exclusive, and notorious possession of alienable and disposable public domain lands under a bona fide ownership claim since June 12, 1945 or earlier. Section 14(2) concerns acquisitive prescription of patrimonial (formerly public domain) lands and requires an express government manifestation under Article 422 before prescription may run.
Supreme Court’s Analysis and Ruling
The Supreme Court agreed with petitioner that respondent never invoked Section 14(2) and thus Article 422 was inapplicable. Focusing on Section 14(1), the Court found that factual determinations by the CA were grounded on misapprehension of evidence and were contrary to
...continue readingCase Syllabus (G.R. No. 248306)
Antecedents and Procedural History
- On September 3, 2015, Science Park of the Philippines, Inc. (SPPI), represented by its Executive Vice-President and General Manager Richard Albert I. Osmond, filed an application for original registration of title under Section 14(1) of Presidential Decree No. 1529 (PD 1529) before the Regional Trial Court (RTC) of Tanauan City, Batangas.
- By Order dated September 10, 2015, the RTC delegated the hearing and disposition of the application to the Municipal Circuit Trial Court (MCTC) of Malvar-Balete pursuant to Administrative Circular No. 6-93-A.
- The Republic of the Philippines, through the Office of the Solicitor General (OSG), entered its appearance, but the MCTC issued an Order of General Default on April 26, 2016 when no oppositor appeared.
- SPPI’s application was docketed as Land Registration Case No. N-138 before the MCTC; on April 12, 2017 the MCTC granted the application, and on July 9, 2019 the Court of Appeals denied the OSG’s motion for reconsideration.
- The Republic filed a petition for review under Rule 45 of the Rules of Court, invoking this Court’s discretionary appellate jurisdiction to reverse the Court of Appeals’ Decision and Resolution in CA-G.R. CV No. 109103.
Facts of Ownership and Land Classification
- The subject property is a 5,255-square-meter parcel designated as Lot No. 3394, Psc-47, Malvar Cadastre, situated in Barangay Luta Sur, Malvar, Batangas.
- SPPI acquired the property by Deed of Absolute Sale from Antonio A. Aranda dated January 6, 2014.
- SPPI and its predecessors-in-interest allegedly held open, continuous, exclusive and notorious possession of the land since June 12, 1945 or earlier.
- Chain of title and possession as testified and documented:
• January 29, 1944: Segunda Kalaw sold to sister Micaela Kalaw
• November 5, 1953: Micaela’s heirs sold to Crisanto Laydia and Agrifina Arcillas
• June 26, 1996: Antonio A. Aranda bought from Crisanto Laydia
• January 6, 2014: SPPI bought from Antonio A. Aranda - The oldest tax declaration on record was dated 1955 in Segunda Kalaw’s name, confirmed by a representative of the Office of the Municipal Assessor of Malvar.
- Witnesses from DENR, DENR-CENRO, Batangas City and NAMRIA testified that Lot 3394 is within the alienable and disposable portion of the public domain, as shown on Land Classification Map No. 3601 and DENR Administrative Order No. 97-37 (December 22, 1997).
- SPPI presented technical documents including: the Sepia copy of Plan (Lot 3394, Psc-47, Malvar Cadastre) bearing an annotation that the lot is within the alienable and disposable zone certified July 21, 2014.
Ruling of the Municipal Circuit Trial Court
- By Decision dated April 12, 2017, the MCTC, upon confirmation of the Order of Gen