Republic of Philippines vs. Science Park of the Philippines, Inc.

To secure judicial confirmation of imperfect title under Section 14(1) of Presidential Decree No. 1529, an applicant must prove by clear, positive, and convincing evidence that: (a) the land forms part of the alienable and disposable lands of the public domain at the time of filing the application; and (b) the applicant and its predecessors-in-interest have been in open, continuous, exclusive, and notorious possession and occupation of the land under a bona fide claim of ownership since June 12, 1945 or earlier. Proof of specific acts of ownership—such as the nature and extent of cultivation, the number of crops planted, or the volume of produce harvested—is essential to substantiate the claim; mere casual cultivation or unsubstantiated assertions of possession are insufficient to overcome the presumption of State ownership.

Science Park of the Philippines, Inc. (SPPI) filed an application for original registration of a 7,691-square meter parcel of land denominated as Lot 5809, Psc-47, Malvar Cadastre, located in Barangay Luta Norte, Malvar, Batangas. SPPI claimed that the land formed part of the alienable and disposable land of the public domain and that it acquired ownership through a chain of transactions originating from Gervacio Lat, who allegedly possessed the land prior to June 12, 1945. The property passed from Gervacio to his daughter Ambrocia Lat, who sold it to Spouses Raymundo Linatoc and Maria Reyes in 1968. Upon their death, their heirs waived their rights in favor of Ernesto Linatoc, who subsequently sold the land to Cenen D. Torizo in 2012. SPPI purchased the land from Cenen through a Deed of Absolute Sale dated October 17, 2013.

• SPPI filed its application for original registration on November 20, 2014, seeking to register a 7,691-square meter parcel of land in Barangay Luta Norte, Malvar, Batangas.
• To prove the land was alienable and disposable, SPPI presented a certification dated February 26, 2016 from the DENR-CENRO Batangas City stating the land was within the alienable and disposable zone under Project No. 39, Land Classification Map No. 3601, based on DENR Administrative Order No. 97-37 (DAO 97-37).
• To prove possession since June 12, 1945 or earlier, SPPI presented Tax Declaration No. 6243 in the name of Gervacio Lat dated 1955, which cancelled a prior tax declaration (TD 1052), though no evidence was presented identifying the declared owner under TD 1052 or its effectivity date.
• SPPI presented testimony from Nelia Linatoc-Cabalda, born in 1936, who claimed that as a child around 1943 (age 7), she knew of Gervacio's ownership because she and other children played on the land and gathered fruits there.
• The chain of title presented was: (1) Gervacio Lat owned the land and held the 1955 tax declaration; (2) his daughter Ambrocia Lat sold it to Spouses Raymundo Linatoc and Maria Reyes via a "Kasulatan ng Bilihang Patuluyan ng Lupa" dated April 25, 1968; (3) upon the spouses' death, their heirs executed an Extrajudicial Settlement with Waiver dated June 4, 1995 in favor of Ernesto Linatoc; (4) Ernesto sold it to Cenen D. Torizo on March 13, 2012; and (5) Cenen sold it to SPPI on October 17, 2013.
• At the MCTC proceedings, the handling Government Prosecutor did not object to the dispensation of the testimony of Jane G. Bautista, Chief of the Records Management and Documentation Division of DENR, regarding the authentication of DAO 97-37, based on a prior stipulation in a related case (LRC No. N-127) involving the same parties.
• The MCTC took judicial notice of DAO 97-37 based on the prosecutor's acquiescence and the fact that the copy presented was certified.

• The Republic argued that SPPI failed to prove the subject land was alienable and disposable because DAO 97-37 was never properly identified in court by the DENR legal custodian of official records, and the MCTC improperly took judicial notice of records from another case (LRC No. N-127).
• The Republic contended that courts are not authorized to take judicial notice of the contents of records of other cases, even when pending in the same court, absent compliance with the requirements of Section 3, Rule 129 of the Rules of Court.
• The Republic asserted that SPPI failed to prove open, continuous, and exclusive possession under a bona fide claim of ownership prior to June 12, 1945, noting that the earliest evidence of possession was the 1955 tax declaration.
• The Republic argued that SPPI failed to identify its predecessors-in-interest prior to 1955 or provide evidence of possession during the critical period from 1945 to 1955.

• SPPI argued that the land was conclusively established to be alienable and disposable through the CENRO certification and DAO 97-37.
• SPPI maintained that the MCTC properly took judicial notice of DAO 97-37 because the handling Government Prosecutor acquiesced to the dispensation of Ms. Bautista's testimony and verified that the copy presented was certified, satisfying the exception to the general rule under Section 3, Rule 129.
• SPPI claimed that it adequately proved possession since June 12, 1945 through testimonial evidence (Nelia Linatoc-Cabalda's testimony regarding Gervacio's possession in 1943) and documentary evidence showing the continuous chain of possession from Gervacio through successive vendees to SPPI.
• SPPI argued that the 1955 tax declaration (TD No. 6243), which cancelled TD 1052, reasonably indicated that possession existed prior to 1955, even if the exact date of the prior declaration was unknown.

• Procedural:
  • Whether the Court of Appeals erred in upholding the MCTC's taking of judicial notice of the records in LRC No. N-127 regarding the dispensation of Ms. Bautista's testimony and the authenticity of DAO 97-37.
• Substantive Issues:
  • Whether the subject land is alienable and disposable land of the public domain.
  • Whether SPPI proved that it and its predecessors-in-interest were in open, continuous, exclusive, and notorious possession and occupation of the land under a bona fide claim of ownership since June 12, 1945 or earlier.

• Procedural:
  • The Supreme Court held that the CA did not err in affirming the MCTC's taking of judicial notice. While the general rule prohibits courts from taking judicial notice of records in other cases, an exception applies when there is no objection and reference is made to the other case by name and number with opportunity to object. Here, the handling Government Prosecutor did not object to dispensing with Ms. Bautista's testimony based on the prior stipulation in LRC No. N-127, and satisfied himself that the DAO 97-37 presented was duly certified before it was marked as an exhibit. Thus, the requirements for the exception were met.
• Substantive:
  • The Court held that the land is alienable and disposable. Contrary to the Republic's argument, the land need not have been declared alienable and disposable since June 12, 1945; it is sufficient that the land is classified as alienable and disposable at the time of filing the application, which SPPI proved through the CENRO certification and DAO 97-37.
  • However, the Court found that SPPI failed to prove possession since June 12, 1945 or earlier. The 1955 tax declaration (TD No. 6243) only gives rise to the presumption that Gervacio claimed ownership starting in 1955. While it cancelled TD 1052, there was no evidence identifying who was declared under TD 1052 or when it was effective.
  • The testimony of Nelia Linatoc-Cabalda regarding playing on the land as a child around 1943 was insufficient to establish the requisite possession. The Court emphasized that to prove open, continuous, exclusive, and notorious possession, the claimant must show specific acts of ownership such as the nature and extent of cultivation, the number of crops planted, or the volume of produce harvested. Mere casual cultivation or childhood play does not constitute the acts of dominion required.
  • Consequently, SPPI failed to satisfy the burden of proving possession for the duration and of the character required by Section 14(1) of PD 1529.

• Judicial Notice of Records in Other Cases — Courts may not take judicial notice of the contents of records of other cases, even when tried or pending in the same court, except when: (a) there is no objection; (b) reference is made to the other case by name and number or other sufficient designation; and (c) the parties are given opportunity to object. This exception applies to avoid inconvenience and unnecessary repetition of evidence when the opposing party has knowledge and acquiesces.
• Requirements for Original Registration under Section 14(1) of PD 1529 — An applicant for judicial confirmation of imperfect title must prove: (1) the land is alienable and disposable at the time of filing (not necessarily since June 12, 1945); (2) open, continuous, exclusive, and notorious possession; and (3) possession under a bona fide claim of ownership since June 12, 1945 or earlier.
• Open, Continuous, Exclusive, and Notorious Possession — Possession must be: open (patent, visible, apparent), continuous (uninterrupted, unbroken), exclusive (showing exclusive dominion and appropriation to one's own use), and notorious (conspicuous and generally known). Proof requires specific acts of ownership such as the nature and extent of cultivation or volume of produce; casual cultivation is insufficient.
• Presumption from Tax Declarations — The payment of realty taxes and the declaration of land in a person's name gives rise to the presumption that the person claimed ownership and possession only as of the date of the tax declaration.

• "In an application for land registration, it is elementary that the applicant has the burden of proving, by clear, positive, and convincing evidence that its alleged possession and occupation were of the nature and duration required by law."
• "The applicant needs only to show that the land had already been declared alienable and disposable at any time prior to the filing of the application for registration."
• "For purposes of land registration under Section 14 (1) of PD 1529, proof of specific acts of ownership must be presented to substantiate the claim of open, continuous, exclusive, and notorious possession and occupation of the land subject of the application."
• "Actual possession consists in the manifestation of acts of dominion over it of such a nature as a party would actually exercise over his own property."
• "The payment of realty taxes and declaration of the subject land in the name of Gervacio in 1955 gives rise to the presumption that he claimed ownership and possession thereof only in that year."

• Republic v. Naguit — Controlling precedent interpreting Section 14(1) of PD 1529 to mean that land need only be declared alienable and disposable at the time of filing, not since June 12, 1945; adopting the interpretation that "since June 12, 1945" modifies "under a bona fide claim of ownership" and not the classification of the land.
• Dumo v. Republic — Cited for the principle that the applicant has the burden of proving possession and occupation by clear, positive, and convincing evidence, and for the requirements to prove alienability and disposability (original classification and certificate of land classification status).
• Espiritu, Jr. v. Republic — Cited for the enumeration of the three essential requirements under Section 14(1) of PD 1529.
• Republic v. Estate of Santos — Cited for the definition of open, continuous, exclusive, and notorious possession and the requirement to prove the nature and extent of cultivation.
• Republic v. T.A.N. Properties, Inc. — Cited for the requirements to prove alienability and disposability, and for the presumption arising from tax declarations regarding the date of possession.
• Republic v. Candy Maker, Inc. — Cited for the requirement that claimants must show the nature and extent of cultivation to prove possession.
• Republic v. Remman Enterprises, Inc. — Cited for the definition of possession and the requirement of acts of dominion such as planting and harvesting crops.
• Heirs of Malabanan v. Republic — Cited for the presumption that the State owns the land applied for and the applicant's burden to overcome this presumption.
• Pilipinas Shell Petroleum Corporation v. Commissioner of Customs — Cited for the rule on judicial notice and the exception regarding records of other cases.

• Section 14(1), Presidential Decree No. 1529 (Property Registration Decree) — Governs applications for registration of title based on open, continuous, exclusive, and notorious possession since June 12, 1945 or earlier.
• Section 3, Rule 129 of the Rules of Court — Provides that during trial, the court may announce its intention to take judicial notice of any matter and allow parties to be heard thereon; establishes the rule and exception regarding judicial notice of other cases.
• DENR Administrative Order No. 97-37 — The land classification order issued by DENR Secretary Victor O. Ramos on December 22, 1997, declaring certain lands as alienable and disposable.