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Case digest · Confirmation of imperfect title by a corporation; proof of possession since June 12, 1945
Republic vs. Manna Properties, Inc.
A corporation applied to register two lots in La Union. The tax declaration it offered to prove possession since 1945 turned out to be a substitute said to be from 1950, on a form that cites the Local Government Code of 1991.
Facts
September 29, 1994
Manna Properties, Inc., represented by its president, applied to register two parcels of land, Lots 9515 and 1006 in Barangay Pagdaraoan, San Fernando, La Union, measuring around 1,480 square meters.
1995
The initial hearing, first set for February 16, 1995, was reset several times. One new date, April 13, 1995, fell on Holy Thursday, and the National Printing Office needed the printing materials 75 days before the hearing. The court’s order of March 15, 1995 finally set the hearing for July 18, 1995, 125 days later.
The opposition
The Republic opposed, stating that the applicant is a private corporation disqualified under the Constitution to hold alienable lands of the public domain. Manna claimed that its predecessors-in-interest had possessed the land since the 1940s, so the land was already private when Manna acquired it.
1996–2000
The trial court approved the application on February 21, 1996. On December 20, 2000, the Court of Appeals dismissed the Republic’s appeal, and upheld the trial court’s finding that Manna’s predecessors-in-interest had possessed the land as early as 1953.
Issue
Did Manna fail the jurisdictional requirements because the initial hearing was set more than 90 days after the order, and did it prove that its predecessors-in-interest possessed the land since June 12, 1945?
Ruling
Manna met the jurisdictional requirements, but it did not prove possession since June 12, 1945. The Court granted the Republic’s petition, reversed the Court of Appeals and denied the application.
On the first issue, the Court sided with Manna. The applicant has no part in setting the hearing date, the LRA had repeatedly asked for resets because of printing problems with the National Printing Office, and the notice was published in the Official Gazette and a newspaper of general circulation well ahead of the hearing. On the second, the Court explained that a private corporation may apply for confirmation of title if its predecessors-in-interest possessed the land since June 12, 1945 or earlier, because such possession converts the land into private land by operation of law. Although review under Rule 45 is generally limited to questions of law, the Court found that the evidence did not support the lower courts’ conclusions. Exhibit Q-16, offered as the tax declaration proving possession since 1945, was a substitute tax declaration allegedly issued on November 28, 1950, and it did not show when in 1945 the original was issued. Its form stated that it was filed under Sec. 202 of R.A. No. 7160, the Local Government Code of 1991, so the tax declaration would have been issued more than 40 years before the form used came into existence, and Manna gave no explanation. The Court concluded that it was fabricated. The earliest uncancelled tax declaration was dated 1950, the transferee’s affidavit 1955, and a predecessor’s testimony did not specifically cover possession since June 12, 1945. At best, Manna could prove possession since 1952, so the land remained part of the public domain.
“We rule, however, that the land in question has not become private land and remains part of the public domain.”
Doctrine
A private corporation may not hold alienable lands of the public domain except by lease (Art. XII, Sec. 3), but it may apply to confirm title to land that was already private when it acquired it. Under the law then in force, the reckoning point was June 12, 1945: “If the predecessors-in-interest of Manna Properties have been in possession of the land in question since this date, or earlier, Manna Properties may rightfully apply for confirmation of title to the land.” And “Judicial confirmation in such cases is only a formality that merely confirms the earlier conversion of the land into private land, the conversion having occurred in law from the moment the required period of possession became complete.” The applicant bears the burden of proving that possession. (R.A. No. 11573, approved July 16, 2021, has since replaced the June 12, 1945 cut-off with possession for at least 20 years immediately preceding the filing of the application.)
Compare: registration allowed
In Republic vs. Court of Appeals and Spouses Lapiña, G.R. No. 108998, August 24, 1994, the predecessors-in-interest had possessed the land since 1937, so the land was already private when the buyers acquired it, and registration was allowed: the Torrens system “merely confirms, but does not confer ownership.”
Bar tip
A corporation’s application to confirm title turns on proof that the land became private before the corporation acquired it; otherwise Art. XII, Sec. 3 allows a corporation only a lease. Delays in setting the hearing that are not the applicant’s fault do not defeat jurisdiction; publication of the notice is the real jurisdictional requirement. And check the cut-off: June 12, 1945 then, at least 20 years of possession under R.A. No. 11573 now.
Hear it explained
Land Titles Jurisprudence Ep. 5, at 7:32
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This digest is general legal information for education, not legal advice, and it is not a substitute for reading the decision. Quoted passages are taken word for word from the full text.