Republic vs. Buenaventura

Under Republic Act No. 11573, which applies retroactively to pending applications, a duly signed certification by a designated DENR geodetic engineer that the land is part of alienable and disposable agricultural lands, imprinted on the approved survey plan and containing specified references, is sufficient proof of the land's classification, superseding the prior requirement of presenting both a CENRO certification and a copy of the DENR Secretary's original classification approval.

Efren S. Buenaventura filed an application for original registration of title over a 209-square-meter lot in Rodriguez, Rizal, claiming ownership through purchase and continuous possession. The Republic, through the Office of the Solicitor General, opposed the application. The Regional Trial Court granted the application, and the Court of Appeals affirmed the decision. The Republic then elevated the case to the Supreme Court, contesting the sufficiency of the evidence proving the land's alienable and disposable status and the applicant's possession.

• Application and Opposition: On January 11, 2008, respondent Efren S. Buenaventura filed a petition for original registration of title over Lot No. 1788, Cad. 674 in Rodriguez, Rizal. He alleged purchase from Lorenzo Habagat in 1993, continuous possession, and payment of real property taxes. The Republic opposed the application.
• Evidence Presented at Trial: Buenaventura presented testimony and documentary evidence including a Deed of Absolute Sale, a CENRO Certification stating the lot is alienable and disposable, and testimony from LRA and DENR personnel regarding the survey plan and lack of overlapping titles.
• Lower Court Rulings: The RTC granted the application, finding Buenaventura had established ownership. The CA affirmed, holding the CENRO certification was sufficient proof of alienability and that possession was proven.
• Republic's Appeal to the Supreme Court: The Republic argued that the CENRO certification alone was insufficient under prevailing jurisprudence (Republic v. T.A.N. Properties, Inc.), which required a copy of the original classification approved by the DENR Secretary. It also challenged the proof of possession.

• Sufficiency of Proof of Alienable and Disposable Status: Petitioner Republic argued that the CENRO certification presented by Buenaventura is not, by itself, incontrovertible evidence to overcome the presumption that the land is inalienable public domain. It maintained that jurisprudence requires the additional presentation of a copy of the original classification approved by the DENR Secretary.
• Proof of Possession and Ownership: Petitioner contended that Buenaventura failed to prove open, continuous, exclusive, and notorious possession and occupation under a bona fide claim of ownership since June 12, 1945, or earlier. It pointed out discrepancies in the area stated in the Deed of Sale (220 sqm) versus the surveyed lot (209 sqm) and the lack of a technical description in the deed.

• Sufficiency of CENRO Certification: Respondent Buenaventura countered that the certification issued by the CENRO is sufficient to establish that the subject property is alienable and disposable, satisfying the legal requirements for land registration.
• Proof of Possession: Respondent argued that the Court of Appeals correctly ruled that he and his predecessor-in-interest had been in open, continuous, exclusive, and notorious possession and occupation of the subject property.

• Proof of Alienable and Disposable Status: Whether the Court of Appeals erred in finding that the subject land is alienable and disposable based solely on a CENRO certification, without proof of the DENR Secretary's original classification approval.
• Sufficiency of Evidence for Registration: Whether the respondent sufficiently proved his and his predecessor-in-interest's open, continuous, exclusive, and notorious possession and occupation of the land under a bona fide claim of ownership.

• Proof of Alienable and Disposable Status: The CENRO certification alone was insufficient under the law prevailing at the time of the lower court decisions. However, Republic Act No. 11573, which took effect on September 1, 2021, retroactively amended the requirements. Under its Section 7, a certification by a DENR geodetic engineer imprinted on the survey plan is now sufficient proof, provided it contains the specified references. The case was remanded to receive evidence under this new standard.
• Sufficiency of Evidence for Registration: The factual finding of the RTC, as affirmed by the CA, that respondent sufficiently established possession over the subject property is binding on the Supreme Court, as it is not a trier of facts. This finding was not disturbed.

• Retroactive Application of Curative Statutes: Republic Act No. 11573, particularly Sections 6 and 7 amending the Property Registration Decree, is a curative statute intended to simplify and remove ambiguity in land registration laws. As such, it may be applied retroactively to cover applications pending as of its effectivity date, without impairing vested rights.
• Proof of Alienable and Disposable Status (Prior and Current Rule): Prior to R.A. No. 11573, prevailing jurisprudence (Republic v. T.A.N. Properties, Inc.) required an applicant to present both a CENRO/PENRO certification and a copy of the original classification approved by the DENR Secretary. R.A. No. 11573 superseded this by providing that a duly signed certification by a designated DENR geodetic engineer, imprinted on the approved survey plan and containing sworn statements referencing the relevant land classification map and issuance, is sufficient proof.
• Binding Nature of Affirmed Factual Findings: The findings of fact of the trial court, when affirmed by the Court of Appeals, are final and conclusive and are binding upon the Supreme Court, which is not a trier of facts.

• "Clearly, R.A. No. 11573 effectively superseded the requirements in T.A.N. Properties, San Mateo, and Spouses Go... Thus, as the rule now stands, the presentation of a certification signed by the designated DENR geodetic engineer, stating that the land forms part of the alienable and disposable portion of the public domain, shall be deemed sufficient proof that the same is alienable and disposable."
• "By their very nature, curative statutes are retroactive... (and) reach back to past events to correct errors or irregularities and to render valid and effective attempted acts which would be otherwise ineffective for the purpose the parties intended."

• Republic v. T.A.N. Properties, Inc., 578 Phil. 441 (2008) — Cited as the controlling precedent that established the rule requiring both a CENRO certification and a copy of the DENR Secretary's approved classification to prove alienability. The Court noted this rule was superseded by R.A. No. 11573.
• Republic v. Pasig Rizal, Co., Inc., G.R. No. 213207, February 15, 2022 — Cited as a recent En Banc decision that exhaustively discussed the retroactive application of R.A. No. 11573 and the new parameters for proving land classification status.
• Givero v. Givero, 661 Phil. 114 (2011) & Dacanay v. People, 818 Phil. 885 (2017) — Cited for the principle that findings of fact by the trial court, when affirmed by the CA, are binding on the Supreme Court.

• Section 14(1), Presidential Decree No. 1529 (Property Registration Decree) — The governing provision for judicial confirmation of imperfect titles, requiring possession and occupation of alienable and disposable lands since June 12, 1945, or earlier.
• Sections 6 and 7, Republic Act No. 11573 — The amendatory provisions that shortened the required period of possession to 20 years and established that a DENR geodetic engineer's certification is sufficient proof of alienable and disposable status.

• Chief Justice Gesmundo (Chairperson)
• Justice Caguioa
• Justice Inting
• Justice Dimaampao