Case Summary (G.R. No. 217336)
Trial Court Proceedings
The RTC of Bangued issued general default against the Republic, allowed the spouses to present evidence, and oversaw multiple surveys and plan corrections. On March 31, 2006, it granted registration, later amending the decision on June 12, 2008 to reflect an increased area of 262 sqm.
Court of Appeals Ruling
The CA, by Decision dated February 27, 2015, denied the Republic’s appeal. It held that under Section 14(4), PD 1529, the spouses fell squarely within those “who have acquired ownership of land in any other manner provided for by law” by virtue of their purchase. It concluded that the requirements for possession under Section 14(1) were inapplicable.
Issue Presented
Whether the CA misappreciated facts and misapplied the law by failing to require proof of alienability and disposability of the land under PD 1529, and by neglecting the presumption that public lands remain inalienable unless formally declared otherwise.
Supreme Court’s Analysis of PD 1529 Section 14
The Court reaffirmed that Section 14(4) admits purchasers of private or alienable lands, but presupposes that the land is indeed alienable or already private. Paragraphs 1–3 of Section 14 expressly describe alienable public lands or private lands, and paragraph 4’s reference to “any other manner provided by law” cannot dispense with the threshold requirement of alienability.
Regalian Doctrine and Burden of Proof
Under Article 419 of the Civil Code and Section 3, Article XII of the 1987 Constitution, all lands of the public domain are presumed inalienable unless classified as agricultural and declared alienable. The onus rests on the applicant to provide incontrovertible proof—such as executive proclamations, administrative classifications, or legislative acts—showing the land’s conversion from public to private or alienable status.
Failure to Prove Alienability
The spouses relied solely on their deed of sale, tax declarati
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Facts
- On July 18, 1991, Spouses Ildefonso Alejandre and Zenaida Ferrer Alejandre filed an application under Presidential Decree No. 1529 (Property Registration Decree) to register Lot No. 6487, Cad. 536, Ap-CAR-000007 (256 sqm) in Barrio Poblacion, Bangued, Abra.
- They alleged ownership by virtue of a Deed of Absolute Sale dated June 20, 1990 executed by vendor Angustia Lizardo Taleon, and asserted actual occupation of the land.
- The Office of the Solicitor General entered appearance on behalf of the Republic on September 16, 1991.
- The Land Registration Authority (LRA) submitted multiple reports (November 12, 1991; August 20, 1993; April 15, 1998) noting plan discrepancies (“polygon does not close”) and ultimately an amended survey showing an increased area of 262 sqm.
- The trial court issued orders of default, allowed plan corrections, received formal offer of evidence (August 10, 1992), and deemed the case submitted for decision (December 10, 1997). A notice of initial hearing was set for July 25, 2000.
- On June 1, 2000, the Republic filed its Opposition, contending (1) lack of open, continuous, exclusive and notorious possession since June 12, 1945 as required by Section 48(b) of Commonwealth Act No. 141 as amended by PD 1073; (2) absence of genuine muniments of title or tax declarations showing bona fide ownership since 1945; and (3) that the property is public domain not subject to private appropriation.
- The Regional Trial Court (RTC) rendered a Decision on March 31, 2006 granting registration, and an Amended Decisi