Case Summary (G.R. No. 170757)
Applicable Law and Legal Issues
The applicable law is the 1987 Philippine Constitution and Presidential Decree No. 1529 (Property Registration Decree). The primary legal issues are:
- Whether Lot No. 2372 is alienable and disposable public domain.
- Whether petitioners and their predecessors-in-interest have established open, continuous, exclusive, and notorious possession under a bona fide claim of ownership since June 12, 1945 or earlier.
- Whether the prior cadastral case judgment constitutes res judicata barring the present registration application.
- Sufficiency of petitioners’ evidence to sustain their claim of possession and title by prescription.
Facts and Trial Court Decision
In 1987, petitioners filed an application for registration of Lot No. 2372. The private oppositors and the Republic opposed, arguing the land had not been declared alienable and disposable and that a prior final judgment disposed of the issue. Petitioners claimed ownership as heirs of Basilio Millarez, who allegedly purchased the land in 1916 and possessed it until his death in 1947, with petitioners maintaining possession until 1966 before being dispossessed by Zafra. Evidence presented by petitioners included a tax declaration dated 1976 in the names of Basilio’s heirs. The RTC granted registration in favor of petitioners.
Court of Appeals Ruling
The CA reversed the RTC decision, stating classification of public lands is exclusively an executive function and in the absence of official classification or declaration, lands remain inalienable. It relied on a previous cadastral case involving the same lot, which had ruled that Lot No. 2372 belonged to the Republic, thereby invoking res judicata to bar petitioners’ application. The CA also held petitioners failed to prove open, continuous, exclusive, and notorious possession since 1945 or earlier.
Petitioners’ Arguments on Appeal
Petitioners contended that Lot No. 2372 is alienable and disposable due to the long possession of themselves and their predecessors starting in 1916, which converted the land into private property. They argued possession and ownership thus warranted confirmation of registered title and asserted that prior dismissal in cadastral proceedings does not bar subsequent registration application.
Government’s Position and Legal Principles
The Office of the Solicitor General (OSG) maintained that the CA properly decided the factual questions, which are binding unless the appellate court’s findings were contrary to those of the trial court. OSG argued petitioners failed to discharge the heavy burden of proving alienability and the required possession since June 12, 1945. It further stressed that tax declarations and payments are insufficient alone to prove ownership or possession in the concept of an owner.
Legal Standards Regarding Public Domain and Possession
Under the Regalian doctrine enshrined in the 1987 Constitution, all lands of the public domain belong to the State unless positively classified as alienable and disposable by official acts such as presidential proclamations, executive orders, legislative acts, or administrative classification. Public lands not reclassified remain inalienable and cannot be acquired by prescription.
Petitioners bear the burden of proving two thresholds by clear, positive, and convincing evidence: (1) that the land is alienable and disposable; and (2) that possession by themselves or predecessors-in-interest has been open, continuous, exclusive, notorious, and bona fide since June 12, 1945 or earlier, as required by PD 1529, Section 14(1).
Absence of Proof of Alienability
The petitioners did not present any official document or positive act demonstrating classification of Lot No. 2372 as alienable and disposable. There was no presidential proclamation, executive order, government certificate, or legislative enactment establishing the land’s status as alienable. Without such incontrovertible evidence, the land must be presumed public domain and thus inalienable.
Effect of Prior Cadastral Case and Res Judicata
A prior cadastral case previously adjudicated by the court declared Lot No. 2372 as public land belonging to the Republic. The CA ruled that this decision operates as res judicata, barring petitioners’ new registration application on substantially the same cause of action involving the same parties and property. Although judicial declarations that land is public do not absolutely bar subsequent applications for title confirmation if the land is later classified as alienable, petitioners failed to establish such reclassification or compliance with legal requirements.
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Background and Nature of the Case
- Petitioners Pacifico M. Valiao and co-heirs filed an application with the Regional Trial Court (RTC) of Kabankalan, Negros Occidental, seeking registration of title over a parcel of land (Lot No. 2372) located in Barrio Galicia, Ilog, Negros Occidental, totaling approximately 504,535 square meters.
- The application was filed on August 11, 1987. The land in question was claimed by petitioners to have been acquired through inheritance from their uncle Basilio Millarez, who purchased it in 1916.
- Oppositors Macario Zafra, Manuel Yusay, and the Republic, through the Office of the Solicitor General (OSG), filed oppositions to the registration on grounds including: lack of alienability and disposability of the land, res judicata based on a prior cadastral case, and failure to establish possession and ownership.
- The RTC, after trial, granted the petitioners’ application on December 15, 1995, recognizing their ownership and ordering registration, except for Lodovico Valiao who sold his share to Macario Zafra.
- The Court of Appeals (CA), upon appeal by oppositors and the Republic, reversed the RTC ruling on June 23, 2005, denying the application on the basis that the land is part of the inalienable public domain, that res judicata applied due to a prior cadastral case, and petitioners failed to show possession since June 12, 1945 or earlier.
- Petitioners filed a motion for reconsideration which the CA denied on November 17, 2005, prompting the present petition for review under Rule 45 of the Rules of Court before the Supreme Court.
Issues Presented for Resolution
- Whether Lot No. 2372 forms part of the alienable and disposable lands of the public domain.
- Whether petitioners' claim of prescription (acquisition of ownership through possession) is valid over Lot No. 2372.
- Whether the prior decision in Cadastral Case No. 23 constitutes res judicata barring the present application for registration.
- Whether petitioners’ possession, through their predecessors-in-interest, is sufficient to sustain their claim for prescription and registration.
Factual and Evidentiary Findings
- Petitioners assert an ancestral acquisition dating back to 1916 via a handwritten Deed of Sale in Spanish, with possession allegedly continuous from that date until dispossession in 1966.
- Petitioners submitted Tax Declaration No. 9562 dated September 29, 1976 for the property under Basilio Millarez’s heirs as evidence of possession.
- Petitioners’ testimonies indicated possession and improvements on the property but lacked supporting documentary proof for possession from 1916 up to June 12, 1945.
- No positive governmental act, such as a proclamation or administrative classification, proving that the land had been declared alienable and disposable, was presented.
- The prior cadastral case, litigated and adjudicated starting in 1966, conclusively ruled Lot No. 2372 to be public domain belonging to the Republic.
- The CA ruled that such prior judgment barred the subsequent application by res judicata and confirmed the land’s status as inalienable public domain.
Legal Principles and Doctrines Applied
- Regalian Doctrine: All lands of the public domain belong to the State and remain inalienable and indisposable unless officially classified as