Title
Republic vs. Spouses Alonso
Case
G.R. No. 210738
Decision Date
Aug 14, 2019
Republic challenged CA's approval of land registration for spouses Alonso, citing insufficient proof of alienability and disposability; SC reversed, denying registration.

Case Summary (G.R. No. 210738)

Relevant Antecedents

Spouses Alonso filed a petition for the registration of the subject land, claiming it as alienable and disposable public land, previously owned by spouses Rafael C. Montalvo and Manuel a Garnica since 1945. Following the latter's death, their heirs executed an Extrajudicial Settlement Among Heirs and sold the property to spouses Alonso through a Deed of Sale dated January 27, 1998. Spouses Alonso asserted they possessed the property in an open, continuous, exclusive, and notorious manner since time immemorial.

Initial Court Ruling

The Regional Trial Court (RTC) of Iloilo City, Branch 22, dismissed the petition on December 29, 2009, finding that spouses Alonso did not provide sufficient evidence to establish that their possession or that of their predecessors had met legal standards since 1945. After a Motion for Reconsideration was denied, spouses Alonso appealed to the Court of Appeals (CA).

Court of Appeals Decision

In its decision dated May 31, 2013, the CA reversed the RTC's dismissal, granting the registration of the subject land. The CA determined that the requirements for possession had been satisfied and ordered a decree of registration in favor of spouses Alonso.

Petitioner's Arguments

The Republic, through the OSG, appealed to the Supreme Court, asserting that spouses Alonso failed to prove their entitlement to register the land, specifically contesting their evidence regarding alienability and disposability.

Key Legal Issue

The primary legal issue addressed is whether the registration of the subject land was appropriate under existing laws and regulations governing land registration and classification.

Relevant Laws and Requirements

The decision referenced Presidential Decree No. 1529, which sets forth the criteria for land registration applications, particularly focusing on the requirement for applicants to demonstrate open, continuous, exclusive, and notorious possession of alienable and disposable lands since June 12, 1945, or earlier, alongside proof of the land's classification status as disposable.

Evidence of Alienability

The Court noted that showing a land's status as alienable and disposable requires documentation from official government bodies, specifically the Community Environment and Natural Resources Office (CENRO) or the Department of Environment and Natural Resources (DENR). This evidence is vital to validly establish the nature of the land in question.

Absence of Critical Documentation

The Supreme Court concluded that spouses Alonso did not present necessary documentation, such as certifications from CENRO or PENRO that would classify the land as alienable and disposable. The relianc

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