In the case of Republic vs. Manna Properties, Inc., the Supreme Court held that for an application of land registration to be approved, an applicant must sufficiently prove open, continuous, exclusive, and notorious possession of the land since June 12, 1945, or earlier. The Court emphasized that presenting fabricated or insufficient evidence, such as questionable tax declarations, would lead to the denial of the land registration application. This ruling highlights the strict requirements for proving land ownership through possession under Philippine law.

Can a Substitute Tax Declaration Prove Land Possession Since 1945?

The Republic of the Philippines filed a petition against Manna Properties, Inc., seeking to overturn the Court of Appeals’ decision that had favored Manna Properties’ land registration application. Manna Properties applied to register two parcels of land in Barangay Pagdaraoan, San Fernando, La Union. The core legal question was whether Manna Properties met the requirements for original land registration, specifically proving sufficient possession of the property for the period required by law. Petitioner argued that the jurisdictional requirements were not met, and Manna Properties failed to sufficiently prove its possession.

The Supreme Court scrutinized whether Manna Properties complied with the requirements for original registration. The petitioner argued that the trial court exceeded the 90-day period mandated by Presidential Decree No. 1529 (PD 1529) between the order setting the initial hearing date and the hearing itself. The Court clarified that the 90-day period is directory and the delay, not attributable to Manna Properties, did not invalidate the proceedings. It’s the publication of the notice of hearing that confers jurisdiction.

Building on this principle, the Court tackled whether Manna Properties had sufficiently proven its possession of the property for the requisite period. The petitioner contended that the lower courts based their findings solely on tax declarations. The Court acknowledged its general restraint from re-evaluating evidence but recognized an exception because the evidence did not support the lower courts’ conclusions.

The Court highlighted that under Commonwealth Act No. 141 (CA 141), specifically Section 48(b), applicants must prove open, continuous, exclusive, and notorious possession of agricultural lands of the public domain since June 12, 1945, or earlier. If proven, the land is effectively segregated from the public domain by virtue of acquisitive prescription. This possession must be under a bona fide claim of ownership.

However, Manna Properties failed to provide adequate evidence of possession dating back to June 12, 1945. The Court found that the tax declarations presented were insufficient. The offered Exhibit Q-16 was a substitute tax declaration allegedly issued on November 28, 1950, replacing the 1945 tax declaration. The Court stressed the importance of presenting the original 1945 tax declaration to verify that possession began on or before June 12, 1945.

The Court elaborated on the irregularities of Exhibit Q-16, stating that there was a lack of information to verify the existence of the original 1945 tax declaration. Further, the tax declaration form indicated that it was filed under Section 202 of R.A. 7160 (Local Government Code of 1991), while it was purportedly executed in 1950. The totality of these circumstances raised doubts on its authenticity. As a result, the application of Manna Properties had to fail since there was no proof that predecessors-in-interest were in open, continuous and adverse possession of the land in question since 12 June 1945. At best, possession was only since 1952.

FAQs

What was the key issue in this case?	The key issue was whether Manna Properties sufficiently proved open, continuous, exclusive, and notorious possession of the land since June 12, 1945, as required for original land registration.
What is the significance of June 12, 1945?	June 12, 1945, is the reckoning date under Commonwealth Act No. 141. Applicants must prove possession of the land since this date or earlier to qualify for judicial confirmation of title.
Why was the substitute tax declaration deemed insufficient?	The substitute tax declaration, Exhibit Q-16, replaced the original 1945 tax declaration, but it lacked specific information to verify the original declaration’s existence and date.
What did the Court find irregular about the tax declaration form used?	The form used for the tax declaration was dated under R.A. 7160, the Local Government Code of 1991, which was enacted more than 40 years after the tax declaration was allegedly issued in 1950.
What evidence is needed to prove possession since June 12, 1945?	Applicants must present clear, convincing, and incontrovertible evidence, such as original tax declarations, testimonies, and other documents, to prove continuous and adverse possession since June 12, 1945.
What is acquisitive prescription?	Acquisitive prescription is the process by which open, continuous, exclusive, and notorious possession of alienable public land for the period prescribed by law effectively converts such land into private land.
Can a private corporation apply for confirmation of title?	Yes, a private corporation can apply for judicial confirmation of the land without needing a separate confirmation proceeding for its predecessors-in-interest first, provided they meet the possession requirements.
What happens if the evidence is fabricated?	If the evidence presented is fabricated, it leads to the denial of the land registration application and undermines the applicant’s claim to the land.

The Supreme Court’s decision underscores the need for meticulous record-keeping and verifiable evidence when claiming land ownership through possession. Applicants must provide credible documentation that unequivocally demonstrates possession dating back to June 12, 1945, or earlier, to secure a valid land title. Failure to meet these stringent evidentiary requirements will result in the denial of land registration applications, preserving the State’s claim over lands not proven to be privately owned.

For inquiries regarding the application of this ruling to specific circumstances, please contact ASG Law through contact or via email at frontdesk@asglawpartners.com.

Disclaimer: This analysis is provided for informational purposes only and does not constitute legal advice. For specific legal guidance tailored to your situation, please consult with a qualified attorney.
Source: Republic of the Philippines vs. Manna Properties, Inc., G.R. No. 146527, January 31, 2005