**Facts:** This case concerns the application for land registration of a parcel located in Barangay Tibig, Silang, Cavite, known as Lot 9864-A, covering an area of approximately 71,324 square meters. Mario Malabanan, who acquired the property from Eduardo Velazco, sought judicial confirmation of his title, claiming possession and occupation of the land by himself and his predecessors-in-interest for over 30 years. The Regional Trial Court (RTC) in Tagaytay City ruled in favor of Malabanan, citing the property as alienable and disposable land of the public domain based on a certification from the Community Environment and Natural Resources Office (CENRO) dated June 11, 2001.
The Office of the Solicitor General (OSG) appealed the decision to the Court of Appeals (CA), arguing Malabanan’s failure to prove that the property belonged to the alienable and disposable land of the public domain and that the required period of possession had not been met. The CA reversed the RTC’s ruling, referencing the Republic v. Herbieto case, emphasizing that possession before March 15, 1982, the date the land was declared alienable and disposable, could not be counted towards the period of possession required for land registration under Presidential Decree No. 1529 (Property Registration Decree).
Following Malabanan’s death, his heirs took the CA decision to the Supreme Court through a petition for review on certiorari, arguing that the possession of agricultural land prior to its declaration as alienable and disposable should be recognized in the reckoning of the period of possession to perfect title under Commonwealth Act No. 141 (Public Land Act) and the Property Registration Decree.
**Issues:**
1. Whether the Supreme Court should recognize possession of agricultural land before its declaration as alienable and disposable in the computation of the period of possession for land registration.
2. Whether the property in question has been ipso jure converted into private property through prescription, based on the possession by Malabanan and his predecessors-in-interest.
**Court’s Decision:** The Supreme Court denied the petition for review on certiorari, upholding the CA’s decision that Malabanan failed to prove sufficient evidence of possession and occupation since June 12, 1945, or earlier. The Court clarified the rules regarding disposition of public land, emphasizing the importance of the land being classified as alienable and disposable as agricultural land of the public domain at the time of application for registration, provided the applicant’s possession dates back to June 12, 1945, or earlier. The declaration of the land as alienable and disposable is necessary to dispute the presumption that the land is inalienable.
**Doctrine:** Land classification as alienable and disposable is crucial for the computation of the period of possession under Section 14 of the Property Registration Decree. Possession of a parcel of land prior to such classification cannot be considered in the computation of possession for purposes of land registration. Lands not clearly under private ownership are presumed to belong to the State.
**Class Notes:**
– Land Classification: Public lands must be classified as alienable and disposable before they can be subject to possession that counts toward registration.
– Possession Period: For registration under Section 14(1) of the Property Registration Decree, possession since June 12, 1945, or earlier is required.
– Regalian Doctrine: All lands not appearing to be clearly under private ownership are presumed to belong to the State.
– PD 1529 (Property Registration Decree) vs. CA 141 (Public Land Act): Clarified the interaction between these two laws in the context of land registration.
**Historical Background:** The case sheds light on the legal requirements for the judicial confirmation of imperfect titles in the Philippines, specifically the intricacies surrounding the classification of land as alienable and disposable and the legal implications of possession periods preceding such classification. The dispute is reflective of the broader challenges in land registration and title confirmation in the Philippines, emphasizing the importance of clear evidence of possession and the adherence to prescribed legal processes.
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