Requirements for original registration of land title

In Republic of the Philippines vs. Cortez,[1] the Court explained that applicants for original registration of title to land must first establish compliance with the provisions of either Section 14(1) or Section 14(2) of P.D. No. 1529, which state:
Sec. 14. Who may apply. The following persons may file in the proper Court of First Instance an application for registration of title to land, whether personally or through their duly authorized representatives:
(1) Those who by themselves or through their predecessors-in interest have been in open, continuous, exclusive and notorious possession and occupation of alienable and disposable lands of the public domain under a bona fide claim of ownership since June 12, 1945, or earlier. 
(2) Those who have acquired ownership of private lands by prescription under the provision of existing laws.
It must be emphasized that the requirements and bases for registration under these two provisions of law differ from one another. Section 14 (1) mandates registration on the basis of possession, while Section 14 (2) entitles registration on the basis of prescription.[2]

CASES: 
[1] 726 Phil. 212, 220-221 (2014).
[2] Espiritu v. Republic, G.R. No. 219070, 21 June 2017.

In Republic v. RRDC (G.R. No. 190817. Jan. 10, 2018), a reading of the application submitted by RRDC was found by the Supreme Court unavailing. In its application, RRDC alleged that it and its predecessors-in-interest "had been in open, continuous, adverse, and peaceful possession in concept of owner of the subject property since time immemorial or for more than thirty years." This allegation made it unclear whether registration is sought under Section 14(1) - possession since 12 June 1945 or earlier; or under Section 14(2) - possession for more than thirty years.

An examination of the RTC decision also proved futile considering that, and as previously pointed out, aside from enumerating the exhibits offered by the applicant, the trial court did not discuss how these pieces of evidence established the requisites for registration. Thus, for the proper resolution of the issues and arguments raised herein, it becomes necessary for the present application to be scrutinized based on the requirements of the provisions of Sections 14 (1) and (2) of P.D. No. 1529.

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