Facts:
Gordoland Development Corp. (petitioner) engaged in real property development filed an application on November 18, 1996, at the RTC, Branch 55, Mandaue City, for the original registration of title over eight parcels of land in Lilo-an, Cebu totaling 86,298 square meters. It claimed that its title to the parcels was obtained in 1995 through deeds of sale and assignments of rights from previous possessors who had supposedly maintained open, continuous, exclusive, and notorious possession of the lands, potentially qualifying them for acquisitive prescription under existing laws.
The petitioner presented testimony and documentary exhibits to support its claim, including tax declarations and certifications from the Register of Deeds and CENRO indicating no existing titles or public land applications for these parcels. A pivotal exhibit was a 1996 CENRO certification suggesting the lands were within an alienable and disposable block, yet it lacked a list of lot numbers and was not formally offered as evidence, nor was its original submitted.
The State opposed the application, raising questions about the sufficiency of evidence for the petitioner’s open, continuous, exclusive, and notorious possession since 1945 or prior, the competency of documents to prove bona fide acquisition or possession, the relevance of any Spanish title or grant, and the constitutional disqualification of private corporations from holding alienable lands of the public domain.
On January 16, 1998, the trial court ruled in favor of Gordoland, ordering the issuance of titles for the eight parcels. Following the State’s appeal, the Court of Appeals reversed this decision, noting deficiencies in Gordoland’s application and evidence regarding the alienability and disposability of the lands, and Gordoland’s failure to prove the requisite 30-year possession.
Issues:
1. Whether the petition for land registration was defective due to alleged unauthorized representation and deficient certification of non-forum shopping.
2. Whether Gordoland failed to demonstrate that the subject properties were alienable and disposable public lands.
3. Whether the petitioner and its predecessors failed to satisfy the legal requirement of 30-year possession for registration.
Court’s Decision:
The Supreme Court concurred with the Court of Appeals on all issues. It held that non-compliance with the verification requirement of the petition does not necessarily render it fatally defective, especially since the authorization issue was later ratified by Gordoland’s board. However, on the substantial matters, the Court found Gordoland’s evidence insufficient to establish that the lands were alienable, disposable, and subject to private appropriation. The absence of concrete proof that the parcels had been declared alienable and disposable by the government rendered the precise duration of possession by Gordoland and its predecessors irrelevant for registration purposes. Hence, the petition was denied.
Doctrine:
This case reiterates the principles concerning the registration of land titles in the Philippines, particularly the stringent requirements for proving that lands sought to be registered are alienable and disposable public lands. It underscores the necessity of presenting conclusive evidence to support claims of possession and ownership over public lands for acquisitive prescription.
Class Notes:
– Verification and certification of non-forum shopping are formal, not jurisdictional, requirements. Non-compliance may be rectified and does not automatically invalidate a petition.
– Clear, unequivocal evidence must establish that land subject to registration as private property is alienable and disposable, with reference to a specific government declaration to this effect.
– Possession and occupation for acquisitive prescription must be open, continuous, exclusive, and notorious, referencing a government declaration of the land as alienable and disposable.
Historical Background:
Gordoland Development Corp. vs. Republic of the Philippines highlights the tension between private property claims and the State’s stewardship over lands of the public domain within the Philippine legal system’s framework. The case reflects ongoing challenges in land registration processes, emphasizing the protection of public lands from private appropriation without clear, legal bases and the government’s role in classifying lands as alienable and disposable to facilitate their transfer to private ownership under prescribed conditions.
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