### Facts:
On September 17, 2002, Corazon C. Sese and Fe C. Sese filed an application for the original registration of land with the Municipal Trial Court of Pulilan, Bulacan, claiming ownership over a 10,792 square meter parcel of land in Barangay Sto. Cristo, Pulilan, Bulacan based on a donation inter vivos from their mother in 1972. They submitted various documents including Tax Declarations, a Certificate of Technical Description, an Official Receipt of real property tax payment, a Certification from the Municipal Treasurer, and a survey plan indicating that the land was alienable and disposable, which was approved by the DENR.
The MTC issued an Order setting the case for hearing following compliance with publication, mailing, and posting requirements. Only Corazon testified concerning their claim. The Office of the Solicitor General (OSG) did not present any evidence to counter the application.
On October 3, 2003, the MTC ordered the registration of the title in the respondents’ names, concluding that they, or their predecessor-in-interest, had shown possession of the land since time immemorial, making it private property.
The OSG appealed to the Court of Appeals (CA) which dismissed the appeal and affirmed the MTC’s decision.
### Issues:
1. Whether the proof presented was sufficient to classify the subject land as alienable and disposable.
2. Whether the CA erred in granting the application for land registration.
### Court’s Decision:
The Supreme Court granted the petition, reversing the CA and MTC decisions. It ruled that the respondents failed to sufficiently prove that the subject land was alienable and disposable as required by law. The notation in the survey plan approved by the DENR was insufficient without an express declaration by the State. Moreover, the evidence did not establish that the respondents’ possession dated back to June 12, 1945, or earlier. Consequently, the Court held that the respondents were not entitled to the registration of the land title under either Section 14(1) or Section 14(2) of Presidential Decree No. 1529 due to the failure to prove that the property is alienable and disposable and lack of proof of possession since June 12, 1945, or earlier.
### Doctrine:
This case reiterated the necessity for applicants for land registration to incontrovertibly prove that the land sought to be registered is alienable and disposable by an explicit declaration by the State. Furthermore, it emphasized that possession and occupation of the land by the applicant or their predecessors-in-interest since June 12, 1945, or earlier should be established beyond doubt.
### Class Notes:
– **Alienable and Disposable Land:** Applicants for land registration must prove with incontrovertible evidence that the land has been declared alienable and disposable by the State.
– **Proof of Possession:** Applicants must also demonstrate open, continuous, exclusive, and notorious possession and occupation since June 12, 1945, or earlier.
– **Regulatory Framework:** The case falls under the purview of Presidential Decree No. 1529 and Commonwealth Act No. 141 (as amended).
– **Relevance of Evidence:** Notations by surveyor-geodetic engineers in survey plans and tax declarations, while relevant, are not conclusive evidence of ownership or the alienable and disposable nature of land.
### Historical Background:
This case reflects the stringent requirements imposed by Philippine law on the registration of land titles particularly concerning lands that are presumed to belong to the public domain. The adherence to principles established in previous jurisprudence, like the doctrine that lands of the public domain are presumed inalienable until proven otherwise, underscores the protective stance adopted towards national resources. The decision reinforces the balance between the State’s preservation of public lands and the recognition of individual rights stemming from long-term occupation and use.
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