### Facts:
A complex case about land registration began when the Espiritu siblings, asserting ownership by inheritance, sought to register a parcel of land (6,971 sqm in La Huerta, Parañaque City) under their names. The property, known as Lot 4178 of the Parañaque Cadastre, has allegedly been in their family’s possession for over thirty years. The Regional Trial Court (RTC) accepted the case and proceeded with the trial, where the Espiritus managed to present four witnesses to support their claim. They introduced various documents, including a DENR-NCR certification highlighting the land’s alienable and disposable status.
Following evidence presentation, the RTC ruled in favor of the Espiritus, granting the application for registration. However, the Republic of the Philippines, represented by the Office of the Solicitor General (OSG), contested this ruling. The OSG’s motion for reconsideration with the RTC was denied, leading to an appeal to the Court of Appeals (CA).
The CA overturned the RTC’s decision, asserting that the Espiritus failed to satisfy the stringent requirement of proving the land’s alienable and disposable status through a CENRO/PENRO certification and a copy of the original classification approved by the DENR Secretary. The CA’s judgment was based on existing jurisprudence, emphasizing the necessity of strict compliance with these requirements for land registration.
### Issues:
1. Whether the CA erred in reversing the RTC’s decision and dismissing the Espiritus’ application for land registration.
2. Whether the DENR-NCR certification suffices to establish the subject land as alienable and disposable for the purposes of registration.
3. Whether the Espiritus sufficiently proved possession and occupation of the subject land under a bona fide claim of ownership since June 12, 1945, or earlier.
### Court’s Decision:
The Supreme Court denied the Espiritus’ petition, affirming the CA’s decision. The Court highlighted that the petitioners failed to meet the stringent requirements for proving the land’s alienable and disposable character, as required under Sections 14(1) and (2) of Presidential Decree No. 1529. Specifically, the petitioners did not present a CENRO/PENRO certification coupled with a certified true copy of the original classification by the DENR Secretary showing the land’s status.
Furthermore, the Court determined that the petitioners did not convincingly prove open, continuous, exclusive, and notorious possession and occupation of the land since June 12, 1945, or earlier. The testimonies and documents provided were deemed insufficient to establish the claimed period of possession under a bona fide claim of ownership.
### Doctrine:
This case reaffirms the “strict compliance” doctrine in land registration cases, specifically the requirement to provide a CENRO/PENRO certification and a certified true copy of the original classification by the DENR Secretary to prove the alienable and disposable status of the land being registered. It also underscores the importance of substantiating claims of possession and occupation since June 12, 1945, or earlier, under a bona fide claim of ownership, for applications under Section 14(1) of P.D. 1529.
### Class Notes:
– **Strict Compliance in Land Registration**: Applicants must provide unequivocal evidence proving the land’s alienable and disposable status, specifically through CENRO/PENRO certification and DENR Secretary’s original classification.
– **Proving Possession for Land Registration**: Claims of ownership must be supported by clear and convincing evidence of open, continuous, exclusive, and notorious possession since June 12, 1945, or earlier.
– **Legal Statutes/Provisions**: Section 14(1) and (2) of P.D. No. 1529 govern the requirements and basis for the registration of land titles, emphasizing possession and prescription, respectively.
### Historical Background:
This case illustrates the evolving jurisprudence regarding land registration in the Philippines, particularly the stringent requirements enacted to prevent fraudulent claims and ensure that only rightful owners are awarded titles to public domain lands. The “strict compliance” principle highlights the judiciary’s stance on rigorously vetting applications to uphold the integrity of land ownership and registration processes.
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