FACTS:

On June 29, 1976, Maria P. Lee applied for the registration of a parcel of land. The Director of Lands opposed the application, arguing that the land had not been acquired under any recognized mode and was still part of the public domain. The Court of First Instance, however, ruled in favor of Lee, confirming her title over the land. The Republic of the Philippines appealed this decision to the Intermediate Appellate Court, which upheld the lower court's ruling. The Republic then filed a petition for review with the Supreme Court.

The main issue to be resolved in this case is whether the mere statement by the applicant that the land had been in the possession of her predecessors-in-interest for more than 20 years constitutes "conclusive evidence" required in land registration cases. The evidence presented during the trial supported the claim that the land was originally owned by Urbano Diaz and Bernarda Vinluan. They sold separate half portions of the land to Laureana Mataban and Sixto Espiritu, who in turn sold their half portions to Maria P. Lee. At the time of the application for registration, Lee had been in possession of the land for approximately thirteen years. She sought to include the possession of her predecessors-in-interest to meet the ownership requirement.

ISSUES:

1. Does the bare statement of the applicant that the land applied for has been in the possession of her predecessors-in-interest for more than 20 years constitute the "well-nigh incontrovertible" and "conclusive" evidence required in proceedings of this nature?

RULING:

1. The Supreme Court ruled in favor of the petitioner, Republic of the Philippines. The evidence presented by the private respondent, Maria P. Lee, did not meet the requirement of "conclusive" evidence to establish her fee simple title or imperfect title which entitled her to registration under the Land Registration Act or the Public Land Act. The mere testimony of Maria P. Lee that her predecessors-in-interest had been in possession of the land for more than 20 years is not sufficient to establish a bona fide claim of acquisition of ownership.

PRINCIPLES:

• In land registration cases, the applicant must present "conclusive" evidence to establish their fee simple title or imperfect title that qualifies for registration under the Land Registration Act or the Public Land Act.

• Mere testimony, without supporting evidence, is not enough to establish a bona fide claim of acquisition of ownership in land registration cases. The evidence presented must meet the quantum of proof required for registration.