Republic vs. Rayos Del Sol

Tax declarations, though not conclusive evidence of ownership, constitute proof of a claim of title and serve as sufficient basis for inferring possession in the concept of an owner; when coupled with credible testimonial evidence establishing possession since June 12, 1945 or earlier, they satisfy the requirements for original registration of imperfect title under Section 14(1) of P.D. No. 1529.

Felipe Del Sol cultivated Lot 8173-A in Barangay Ligid Tipas, Taguig during his lifetime until his death on July 2, 1932. His son, Jose Rayos Del Sol, continued farming the land until his death on September 25, 1953. The respondents, children of Jose and grandchildren of Felipe, inherited the property and continued possession through tenants. The land, part of the alienable and disposable public domain per L.C. Map No. 2623 certified on January 3, 1968, was declared for taxation purposes as early as 1948.

• Nature of the Application: On January 16, 2009, respondents Cesar, Lydia, Gloria, and Elvira Rayos Del Sol filed an application for land registration of Lot 8173-A (33,298 square meters) under Section 14(1) of P.D. No. 1529, alleging inheritance from their father Jose and grandfather Felipe.
• Chain of Possession: Felipe Del Sol possessed and cultivated the land with rice, vegetables, and fruit trees until his death in 1932. Jose Rayos Del Sol continued farming until his death in 1953. Respondents thereafter possessed the land through caretakers and tenants.
• Subdivision and Sale: On January 4, 2004, Lot 8173 was subdivided into four parcels. In 2006, the Republic, through DPWH, purchased Lot 8173-A-2 (1,138 square meters) from respondents via Deed of Absolute Sale.
• Evidence Presented: Respondents presented the Extrajudicial Settlement of Felipe's Estate (August 3, 1996), tax declarations from 1948 to 2006, a Conversion Subdivision Plan, and testimonies of Lydia Rayos del Sol-Alcantara and Gloria Serviño (tenant's wife).
• Testimonial Evidence: Lydia testified that her family had been in open and continuous possession for over seventy years since her grandfather's time. Gloria testified that her father had been a tenant of Jose since 1942, and her husband continued farming the land under a "buwisan" arrangement with respondents, with no other claimants known.

• Insufficient Period of Possession: The Republic argued that respondents failed to prove possession since June 12, 1945, as the earliest tax declaration presented was dated 1948, falling short of the statutory requirement.
• Inconclusive Tax Declarations: Tax declarations are not conclusive evidence of ownership or possession and cannot establish the character of possession required by law.
• Deficient Testimonial Evidence: The testimonies were general in character and bereft of specific overt acts demonstrating possession or dominion over the land.
• Improbable Testimony: Lydia could not have observed her grandfather Felipe cultivate the land because he died in 1932, five years before her birth in 1937.
• Irrelevant Document: The Deed of Absolute Sale pertained to Lot 8173-A-2, not the subject Lot 8173-A, and thus was irrelevant to the registration proceedings.

• Credible Testimonial Evidence: Respondents countered that Lydia's and Gloria's testimonies sufficiently established open and continuous possession through predecessors-in-interest even before June 12, 1945. Gloria's testimony that her father was already a tenant in 1942 bolstered possession since before 1945.
• Tax Declarations as Evidence: Tax declarations, combined with testimonial evidence, were sufficient to prove possession in the concept of an owner for the required period.
• Relevance of Deed of Sale: Although the sale covered only Lot 8173-A-2, this parcel was undeniably a portion of Lot 8173-A, and the Republic's purchase acknowledged respondents' ownership.

• Compliance with Section 14(1): Whether respondents established that they and their predecessors-in-interest have been in open, continuous, exclusive, and notorious possession and occupation of the subject property under a bona fide claim of ownership since June 12, 1945 or earlier.
• Sufficiency of Evidence: Whether tax declarations dated 1948 and testimonial evidence suffice to prove possession since June 12, 1945.

• Compliance with Section 14(1): The requisites were satisfied. The land was alienable and disposable (certified January 3, 1968). Respondents established possession since before June 12, 1945 through the credible testimonies of Lydia and Gloria, which detailed the chain of possession from Felipe (died 1932) to Jose (died 1953) to respondents.
• Sufficiency of Evidence: Tax declarations constitute proof of a claim of title and serve as sufficient basis for inferring possession in the concept of an owner. When coupled with credible testimonial evidence establishing possession for the required period, the earliest tax declaration need not be dated June 12, 1945 or earlier. The Deed of Sale to the Republic, though covering only a portion, substantiated respondents' allegations of open, continuous possession and the absence of other claimants.

• Section 14(1) of P.D. No. 1529 Requisites: Original registration of imperfect title requires: (1) the land forms part of the alienable and disposable lands of the public domain; (2) open, continuous, exclusive, and notorious possession and occupation under a bona fide claim of ownership; and (3) such possession since June 12, 1945 or earlier.
• Tax Declarations as Indicia of Possession: Tax declarations are not conclusive evidence of ownership but constitute proof that the holder has a claim of title over the property. They are good indicia of possession in the concept of an owner, for no one in his right mind would pay taxes for property not in his actual or constructive possession. When coupled with actual possession, they constitute evidence of great weight and can be the basis of a claim of ownership through prescription.
• Credibility of Testimony Standard: As long as the testimony supporting possession for the required period is credible, the court will grant the petition for registration, even if the earliest tax declaration is dated after June 12, 1945.

• "Tax declarations have probative value in land registration proceedings... The voluntary declaration of a piece of real property for taxation purposes not only manifests one's sincere and honest desire to obtain title to the property, but also announces an adverse claim against the state and all other interested parties with an intention to contribute needed revenues to the government. Such an act strengthens one's bona fide claim of acquisition of ownership."
• "While tax declarations and receipts are not conclusive evidence of ownership and do not prove title to the land, nevertheless, when coupled with actual possession, they constitute evidence of great weight and can be the basis of a claim of ownership through prescription."
• "As long as the testimony supporting possession for the required period is credible, the court will grant the petition for registration."

• Recto v. Republic, 483 Phil. 81 (2004) — Followed for the principle that credible testimony supporting possession for the required period warrants registration.
• Spouses Llanes v. Republic, 592 Phil. 623 (2008) — Followed for the rule that tax declarations coupled with actual possession constitute evidence of great weight for ownership claims.
• Republic v. Santos, 691 Phil. 367 (2012) — Cited for the enumeration of Section 14(1) requisites.
• Mistica v. Republic, 615 Phil. 468 (2009) — Cited regarding tax declarations manifesting sincere desire to obtain title.

• Section 14(1), P.D. No. 1529 (Property Registration Decree) — Governs original registration of imperfect titles based on open, continuous, exclusive, and notorious possession since June 12, 1945 or earlier.
• Section 48(b) in relation to Section 11(4), Commonwealth Act No. 141 (Public Land Act) — Basis for Section 14(1) of P.D. No. 1529 regarding judicial confirmation of imperfect titles.

Carpio (Chairperson), Brion, Del Castillo, and Leonen, JJ.