REPUBLIC OF THE PHILIPPINES, vs. THE COURT OF APPEALS AND SPOUSES MARIO B. LAPIÑA AND FLOR DE VEGA.
- G.R. Number: G.R. No. 108998
- Promulgated: 1994-08-24
- Ponente: Bidin, J.
Doctrine
Possession of alienable and disposable public lands of the character and duration prescribed by statute may be tacked from predecessors-in-interest and treated as equivalent to an express government grant for purposes of confirmation of title.
Section 48(b)'s conclusive presumption that a possessor meeting statutory requirements has performed conditions essential to a government grant precludes proof to overcome that presumption in confirmation proceedings.
For purposes of transfer/acquisition of private land, it suffices that transferees were formerly natural-born Filipinos; their subsequent naturalization does not bar registration of the parcels they acquired while Philippine citizens.
Facts
The case concerns application for registration of title over Lots 347 and 348 (Ap-04-003755) by spouses Mario B. Lapiña and Flor de Vega, formerly natural-born Filipinos but later Canadian citizens by naturalization.
The Republic sought review, asking the Court to rule that a foreign national cannot apply for registration of title over land purchased while still a Filipino citizen from a vendor who complied with the Public Land Act.
Respondents' predecessors-in-interest had open, continuous, exclusive and notorious possession of the disputed public land since at least 12 June 1945, and the statutory period of possession was tacked to their possession.
The Court noted statutory dictum (Section 48[b]) that possession meeting statutory character and duration creates a conclusive presumption of compliance with grant requirements entitling the possessor to a certificate of title.
Issues
Whether a foreign national may apply for registration of title over land acquired by purchase while he was still a Philippine citizen from a vendor who complied with the Public Land Act.
Whether former natural-born Filipino transferees who later naturalized as foreign citizens may register transfer/acquisition of private land.
Ruling
The petition is dismissed and the appellate decision affirming registration in favor of spouses Lapiña and de Vega is affirmed; the Court approves the application and confirms title and possession over Lots 347 and 348 and directs issuance of decree and certificate of title (with noted easement).
Keywords
G.R. No. 108998, Public Land Act (CA 141), registration of title, foreign national, Canadian citizenship through naturalization, Regalian doctrine, confirmation of title, Property Registration Decree, Presidential Decree No. 1529, alienable and disposable zone, Bureau of Forest Development, Torrens System, Municipality of Victorias vs. Court of Appeals, G.R. No. L-31189, Bollozos vs. Yu Tieng Su, G.R. No. L-29442, private lands, constitutional prohibition, ownership, registration, application, title