FACTS : Respondent spouses Rolly D. Tan and Grace Tan filed an application for the confirmation and registration of title over a 208-square-meter parcel of land in Batangas City, alleging that they acquired the property in 2003 and 2004 from the heirs of Cirilo Garcia and Simeon Garcia. To support their application, they submitted tax declarations, tax payment receipts, technical descriptions, and certifications from the City Assessor and City Treasurer. During trial, the respondents presented evidence from the Community Environment and Natural Resources Office (CENRO), including a certification and an inspection report stating that the property was within an alienable and disposable zone under Land Classification Map No. 718. Witnesses likewise testified that respondents and their predecessors-in-interest had openly and continuously possessed the property, while the City Assessor explained that earlier tax records were unavailable because they had been destroyed in a fire in 1979.
The Municipal Trial Court in Cities (MTCC) granted the application, finding that respondents had established open, continuous, exclusive, notorious, and adverse possession of the property by tacking their possession to that of their predecessors-in-interest for more than forty years. It also relied on the CENRO certification and inspection report confirming that the property formed part of the alienable and disposable public domain. On appeal, the Court of Appeals (CA) affirmed the MTCC's ruling, holding that respondents substantially complied with the requirement of proving the property's alienable and disposable status by presenting the CENRO certification, the inspection report, and the approved subdivision plan bearing the annotation that the land was within an alienable and disposable area. The CA further ruled that respondents sufficiently established possession through tax declarations, tax payments, improvements on the property, and the testimony of their witness, Felicidad Lumanglas, whose credibility was not impaired despite her young age in 1945 because her testimony was based on her long familiarity with the property and its occupants. Finding no reversible error, the CA denied the appeal and later denied the Office of the Solicitor General's motion for reconsideration.
ISSUE : WON the CA erred in affirming the trial court's Decision
HELD : The Supreme Court held that although the petition for land registration could not yet be finally granted, neither should it be outright denied because the enactment of Republic Act No. 11573 during the pendency of the case substantially changed the legal requirements for judicial confirmation of imperfect land titles and applies retroactively to pending cases. The Court relied heavily on Republic v. Pasig Rizal Co., Inc., which clarified that applicants now need only prove open, continuous, exclusive, and notorious possession of alienable and disposable public land for at least twenty (20) years immediately preceding the filing of the application, instead of possession since June 12, 1945, and that an approved survey plan with the required certification of a duly designated DENR geodetic engineer is now sufficient to establish the land's alienable and disposable status, replacing the stricter evidentiary requirements under earlier cases. While the respondents had presented tax declarations dating back to 1968 and 1974 and proof of tax payments, the Court found that their evidence on actual possession and occupation by their predecessors-in-interest was insufficient because the testimony of their witness lacked specific details establishing continuous possession from at least March 11, 1989 (twenty years before the filing of the application on March 11, 2009). Consequently, the Supreme Court denied the petition only in part, set aside the Court of Appeals' decision, and remanded the case for a limited trial to allow respondents to present additional evidence complying with the new requirements of R.A. No. 11573, particularly regarding the land's classification as alienable and disposable and proof of continuous possession and occupation by their predecessors-in-interest before the Court of Appeals resolves the case anew.
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