Republic vs. Maria Lee and IAC, G.R. No. 64818, May 13, 1991 (197 SCRA)

“failure to prove bonafide claim to land through tacking possession from predecessor-in –interest to meet requirements provided by law”

Facts:

Respondent filed before the RTC a registration of a parcel of land in her favor which was opposed by the Dir. Of Lands on grounds that respondent or her predecessor-in-interest acquired the land under any recognized mode for acquisition of title; they have not been in open, continuous, exclusive, notorious possession of the land in the concept of an owner for at least 30 years prior to the filing of application and the land in dispute is a public domain belonging to Republic of the Philippines. The court rendered judgment in favor of respondents. Upon appeal by RP, it affirmed the lower court decision thus this appeal to the Supreme Court.

Republic of the Phil. contends that respondent failed to prove by conclusive evidence that she has ownership of the land by fee simple title and her testimony as to the ownership of her predecessor-in-interest is self serving after claiming that she obtained her Deed of Sale of the property from Laureana Mataban and Sixto Espiritu who obtained their title from the previous owners of the land, Urbano Diaz and Bernarda Vinluan. From the time of filing the application of registration, the respondent was in possession of the land for 13 years but she sought to tack her possession on the said land from her predecessor-in-interests who were in possession of the land for 20 years. Conditions provided by Sec. 48 (b) of Commonwealth Act No. 141 where one is under a bonafide claim of acquisition of ownership through their predecessor-in-interest or by themselves have been in open, continuous, exclusive and notorious possession and occupation of the agricultural land in public domain for 30 years shall be entitled to a certificate of title.

Issue:

Whether or not the respondent is able to provide sufficient and substantial evidence as complying with the requirement of law for confirmation of her ownership of the land in dispute?

Ruling:

In is held that it is incumbent upon the respondent to prove that her predecessor-in-interest is the persons of Urbano Diaz and Bernarda Vinluan have been in adverse, continuous, open, public, peaceful possession in the concept of an owner for 20 years which she failed to provide a clear and convincing evidence to prove. Her bare allegations do not constitute substantial proof. Respondent failed to comply with the requirements of the law to confirm her title on the land applied for registration. Lower court decision was set aside.

Underlying Principle: All lands not acquired from the government belong to the state as part of public domain.