Republic v. Manimtim (G.R. No. 169599. March 16, 2011)

CASE DIGEST: REPUBLIC OF THE PHILIPPINES, Petitioner, v. JUANITO MANIMTIM, ET AL., Respondents. Republic v. Manimtim (G.R. No. 169599. March 16, 2011).

FACTS: Respondents filed with the RTC two applications for registration and confirmation of their title over two (2) parcels of land located in Barangay Sungay, Tagaytay City. The respondents alleged that they are the owners pro indiviso and in fee simple of the subject parcels of land; that they have acquired the subject parcels of land by purchase or assignment of rights; and that they have been in actual, open, public, and continuous possession of the subject land under claim of title exclusive of any other rights and adverse to all other claimants by themselves and through their predecessors-in-interest since time immemorial. In support of their applications, the respondents submitted blueprint plans of Lot 3857 and Lot 3858, technical descriptions, certifications in lieu of lost geodetic engineers certificates, declarations of real property tax, official receipts of payment of taxes, real property tax certifications, and deeds of absolute sale.

The OSG opposed the petition, alleging, among others, that the respondents have not proven actual, open, public, and continuous possession of the land from June 12, 1945 or earlier. Moldex Realty also opposed, stating that a part of one of the parcels of the land overlapped with lands it owned.

The RTC handed down its Judgment granting the respondents application for registration of the first lot but deferred the approval of registration of the second lot pending the segregation of 4,243 square meter portion thereof which was found to belong to Moldex. It rendered an amended judgment later, granting registration of the second lot. The OSG and Moldex appealed with the CA, which reinstated the earlier RTC decision. The OSG appealed.

ISSUE: Did the CA err in reinstating the earlier RTC decision, or whether or not the respondents had a valid claim over the two parcels of land?HELD: Applicants for registration of title under Section 14(1) of P.D. No. 1529 in relation to Section 48(b) of Commonwealth Act 141, as amended by Section 4 of P.D. No. 1073 must sufficiently establish: (1) that the subject land forms part of the disposable and alienable lands of the public domain; (2) that the applicant and his predecessors-in-interest have been in open, continuous, exclusive and notorious possession and occupation of the same; and (3) that it is under a bona fide claim of ownership since June 12, 1945, or earlier.

These the respondents must prove by no less than clear, positive and convincing evidence.

The respondents best evidence to prove possession and ownership over the subject property were the tax declarations issued in their names. Unfortunately, these tax declarations together with their unsubstantiated general statements and mere xerox copies of deeds of sale are not enough to prove their rightful claim.Well settled is the rule that declarations and receipts are not conclusive evidence of ownership or of the right to possess land when not supported by any other evidence.The fact that the disputed property may have been declared for taxation purposes in the names of the applicants for registration or of their predecessors-in-interest does not necessarily prove ownership. They are merely indicia of a claim of ownership.