Primary Holding

The application for land registration is denied because the applicant failed to discharge the burden of proving that the subject land is alienable and disposable land of the public domain, a prerequisite for registration under Section 14(1) of the Property Registration Decree.

Background

Rosario de Guzman Vda. de Joson applied for land registration based on her and her predecessors-in-interest's alleged open, continuous, exclusive, and notorious possession and occupation of the land since 1926. The Republic opposed, arguing the land was unclassified forest land and not subject to private appropriation. The CFI and CA ruled in favor of De Joson, but the Republic appealed to the Supreme Court.

Facts

• 1. Rosario de Guzman Vda. de Joson applied for registration of a riceland in Paombong, Bulacan, claiming ownership through inheritance and continuous possession since 1926.
• 2. The land was originally owned and possessed by Mamerto Dionisio since 1907, who sold it to Romualda Jacinto in 1926.
• 3. Maria Jacinto inherited the land from Romualda, and subsequently, Rosario de Guzman Vda. de Joson inherited it from Maria in 1963.
• 4. De Joson presented evidence of tax declarations and tax payments.
• 5. The Republic, through the Director of Lands and Forest Development, opposed, arguing the land was forest land and part of the Labangan Channel operated by the Pampanga River Control System, and thus not subject to registration.
• 6. The Solicitor General also opposed, citing a 1927 BF Map indicating the land was unclassified forest land under the Bureau of Forest Development's jurisdiction.
• 7. De Joson submitted a CENRO certification dated March 8, 2000, stating the land is within Alienable or Disposable Land Project No. 19, Land Classification Map No. 2934 certified on October 15, 1980, but this was submitted late and deemed insufficient.

Arguments of the Petitioners

• 1. The land is part of the unclassified region denominated as forest land of Paombong, Bulacan and thus not subject to land registration.
• 2. The land is a portion of the Labangan Channel operated by the Pampanga River Control System and cannot be subject to appropriation or registration.
• 3. The respondent failed to prove that the land is alienable and disposable land of the public domain.
• 4. Mere possession for 30 years is insufficient without proof of the land's alienable and disposable status as of June 12, 1945 or earlier.
• 5. The CENRO certification submitted late is insufficient to prove the alienable and disposable character of the land.

Arguments of the Respondents

• 1. She and her predecessors-in-interest had been in open, continuous, exclusive, and notorious possession and occupation of the land in the concept of owner since 1926, for more than 30 years.
• 2. She presented documentary evidence including a deed of sale, tax declarations, and tax payment receipts to prove her claim.
• 3. The land is not within any military or naval reservation.
• 4. The CFI and CA correctly found that she had sufficiently proven her right to registration based on unrebutted evidence.
• 5. The land was later certified as alienable and disposable by CENRO.

Issues

• 1. Whether or not the land subject of the application for registration is susceptible of private acquisition.
• 2. Whether or not the lower courts erred in granting the application for registration.

Ruling

• 1. The Supreme Court ruled in favor of the Republic, reversing the CA and CFI.
• 2. The Court held that for land registration under Section 14(1) of the Property Registration Decree, the applicant must prove that the land is alienable and disposable land of the public domain as of June 12, 1945, or earlier.
• 3. The applicant bears the burden of proving these requisites.
• 4. De Joson failed to present sufficient evidence, such as a presidential proclamation or DENR Secretary's declaration, to prove the land was classified as alienable and disposable before filing the application or at least by June 12, 1945.
• 5. The CENRO certification, submitted late, and even if considered, is insufficient by itself as it needs to be supported by the DENR Secretary's original classification approval and certification.
• 6. Mere possession and tax payments are insufficient to overcome the presumption that the land is public domain.
• 7. Reclassification to alienable and disposable land after the application was filed does not cure the defect.

Doctrines

• 1. Regalian Doctrine: All lands of the public domain belong to the State; private ownership must be proven through a positive act of the government.
• 2. Burden of Proof in Land Registration: The applicant for land registration bears the burden of proving all requisites for registration, including that the land is alienable and disposable.
• 3. Positive Act of Government: To prove land is alienable and disposable, there must be a positive act from the government, such as a presidential proclamation or DENR Secretary's declaration, not just a surveyor's notation or CENRO certification alone.
• 4. Prescription against the State: Prescription does not run against the State with respect to public domain lands. Acquisitive prescription for public domain lands only starts when the land is officially declared patrimonial or alienable and disposable.

Key Excerpts

• 1. "All lands of the public domain, waters, minerals, coal, petroleum, and other mineral oils, all forces of potential energy, fisheries, forests or timber, wildlife, flora and fauna, and other natural resources are owned by the State."
• 2. "The applicant for land registration must prove that the DENR Secretary had approved the land classification and released the land of the public domain as alienable and disposable…"
• 3. "Thus, the present rule is that an application for original registration must be accompanied by (1) a CENRO or PENRO Certification; and (2) a copy of the original classification approved by the DENR Secretary and certified as a true copy by the legal custodian of the official records."
• 4. "It is clear that property of public dominion, which generally includes property belonging to the State, cannot be the object of prescription or, indeed, be subject of the commerce of man."
• 5. "In other words, the period of possession prior to the reclassification of the land, no matter how long, was irrelevant because prescription did not operate against the State before then."

Precedents Cited

• 1. Heirs of Mario Malabanan v. Republic: Set guidelines for land registration proceedings and emphasized the need for positive government act to declare land alienable and disposable.
• 2. Republic vs. Tsai: Summarized the amendments to Section 48(b) of the CA 141, predecessor of Section 14(1) of PD 1529, and highlighted the June 12, 1945 cut-off.
• 3. Republic v. Doldol: Provided a summary of amendments to Section 48(b) of CA 141.
• 4. Menguito v. Republic: Held that a geodetic engineer's survey with classification certification is insufficient to prove land's alienable and disposable status.
• 5. Republic v. T.A.N. Properties, Inc.: Explicitly ruled on the requirements for proving land classification and the insufficiency of CENRO certification alone.
• 6. Republic v. Bantigue Point Development Corporation: Reiterated the Regalian doctrine and burden of proof for applicants.
• 7. Republic v. Dela Paz & Mistica v. Republic: Cited for the requisites of Section 14(1).
• 8. Naguit v. Court of Appeals & Bracewell v. Court of Appeals & Republic v. Ceniza: Discussed the timing of land classification in relation to the filing of land registration applications, distinguishing scenarios where application precedes or succeeds the classification.

Statutory and Constitutional Provisions

• 1. Presidential Decree No. 1529 (Property Registration Decree), Section 14 (1) and (2).
• 2. Commonwealth Act No. 141, Section 48(b) (as amended by PD 1073 and RA No. 1942).
• 3. Republic Act No. 6236.
• 4. Act No. 496.
• 5. Civil Code of the Philippines, Articles 420, 422, 1113.
• 6. 1987 Constitution, Article XII, Section 2.