Republic of the Philippines v. Pasig Rizal Co., Inc. (G.R. No. 213207, February 15, 2022) (CASE DIGEST)

Facts

Pasig Rizal Co., Inc. (PRCI) sought original registration of title over a 944-square meter parcel of land in Pasig City (Subject Property), claiming that it and its predecessors-in-interest had been in open, continuous, exclusive, and notorious possession in the concept of an owner since 1956,,. The Regional Trial Court (RTC) and the Court of Appeals (CA) affirmed PRCI’s title, finding the Subject Property alienable and disposable (A&D) based on certifications issued by Department of Environment and Natural Resources (DENR) officials, referencing Land Classification (LC) Map No. 639, approved in 1927,. The Republic, through the Office of the Solicitor General (OSG), appealed, arguing that PRCI failed to present sufficient proof of A&D status as required by jurisprudence (T.A.N. Properties and Hanover) and failed to provide an express government manifestation that the property was no longer retained for public use, as mandated by the Malabanan ruling,,. During the pendency of the appeal before the Supreme Court, Republic Act No. (RA) 11573, which streamlined the confirmation process for imperfect land titles, took effect.

Issues

1. Whether the respondent (PRCI) sufficiently proved entitlement to a decree of registration over the Subject Property, specifically establishing its status as alienable and disposable land of the public domain.
2. Whether the judicial requirement set forth in Heirs of Mario Malabanan v. Republic (requiring an express State declaration to convert property of public dominion into patrimonial property) applies to land that has been classified as alienable and disposable but has not been previously utilized by the State for public purpose,.
3. Whether RA 11573, which amended the requirements for possession and proof of land classification status under Presidential Decree No. (PD) 1529, should be applied retroactively to pending applications for judicial confirmation of title,.

Ruling

WHEREFORE, premises considered, the petition for review on certiorari filed by the Republic of the Philippines is DENIED in part. The February 25, 2014 Decision and June 27, 2014 Resolution respectively rendered by the Court of Appeals First Division and Special First Division in CA-G.R. CV. No. 98531 are AFFIRMED insofar as it holds that Pasig Rizal Co., Inc., by itself and through its predecessors in interest, has been in open, continuous, exclusive, and notorious possession and occupation of the Subject Property since 1956. The case is REMANDED to the Court of Appeals for reception of evidence on the Subject Property’s land classification status based on the parameters set forth in Section 7 of Republic Act No. 11573. Thereafter, the Court of Appeals is directed to resolve the present case in accordance with this Decision with due and deliberate dispatch.

Essential Elements of Jurisprudence

1. Conversion of Public Land to Patrimonial Property: Property of public dominion (Art. 420, Civil Code) becomes susceptible to acquisition by prescription only upon its conversion to patrimonial property (Art. 421 and 422),. The operative act that converts agricultural land forming part of the public dominion to patrimonial property is its classification as alienable and disposable land of the public domain,.
2. Refinement of the Malabanan Doctrine: The strict requirement for an express government manifestation (law or proclamation) that the land is “no longer retained” for public use or service (the second Malabanan requirement) is improper when the property subject of the application has not been previously utilized by the State for some public purpose,,. The necessity for explicit withdrawal from public use (Art. 422) exists only where there has been prior state-use,.
3. Retroactivity of RA 11573: RA 11573, particularly Section 6 (amending PD 1529, Section 14) and Section 7 (proof requirements), is curative and remedial in nature and applies retroactively to all applications for judicial confirmation of title pending as of September 1, 2021,,.
4. New Possession and Presumption (New PD 1529, Sec. 14): The required period of possession for original registration under PD 1529, Section 14(1) is shortened to “at least twenty (20) years immediately preceding the filing of the application”,. Proof of this possession for A&D lands results in a conclusive presumption that the applicant has “performed all the conditions essential to a Government grant”,. This new proviso confirms that A&D classification places the land within the commerce of man and eliminates the need for the second Malabanan requirement,.
5. New Proof of Alienable Status (RA 11573, Sec. 7): Proof of A&D status is now sufficient if it consists of a duly signed certification by a duly designated DENR geodetic engineer imprinted on the approved survey plan. This certification must include references to the relevant issuance (e.g., FO/DAO/EO/Proclamation) and the LC Map number. The DENR geodetic engineer must be presented as a witness for proper authentication,.

Sample Q&A

Question: Applicant A files for judicial confirmation of imperfect title in 2020 over an agricultural land classified as alienable and disposable (A&D) since 1950, proving open, continuous, and exclusive possession since 1980 (40 years). His application is pending appeal when RA 11573 takes effect in 2021. Must Applicant A present an Executive Proclamation or law specifically declaring the land as patrimonial property, or is the A&D classification sufficient to satisfy the requirements for acquisition by prescription under PD 1529?Answer: The A&D classification is sufficient, provided the land was never previously utilized by the State for a public purpose. The provisions of R.A. No. 11573, which took effect in 2021, apply retroactively to pending applications,. Under the new Section 14(1) of P.D. No. 1529 (as amended by R.A. No. 11573, Sec. 6), an applicant needs only prove possession of A&D lands for at least twenty (20) years immediately preceding the filing of the application (which Applicant A satisfies with 40 years of possession),. Upon proving this, the applicant is conclusively presumed to have performed all the conditions essential to a Government grant,. This legislative change effectively clarifies and modifies prior jurisprudence by affirming that the classification of agricultural land as alienable and disposable is the operative act that converts public dominion property to patrimonial property, rendering it susceptible to acquisition by prescription (Civil Code, Arts. 422, 1113),,. The stricter requirement of an express declaration of patrimonial status applies only when the land has been subject to prior state-use and must be explicitly abandoned,.

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