View full case

CHARLES L. ONG v. REPUBLIC

FACTS:

On July 1, 1999, petitioner Charles L. Ong filed an application for registration of title over a lot in Mangaldan, Pangasinan. He claimed to be the co-owner of the lot along with his brothers and alleged that they acquired it through purchase from Tony Bautista and Alicia Villamil on August 24, 1998. They asserted that they and their predecessors-in-interest have been in open, continuous, and peaceful possession of the lot for more than 30 years.

Respondent Republic of the Philippines opposed the application, arguing that the applicants failed to meet the requirements for registration and that the lot is part of the public domain.

The trial court ruled in favor of the petitioners, but the Court of Appeals reversed the decision, stating that the petitioners failed to prove adverse possession of the lot since June 12, 1945 or earlier as required by the law.

The earliest tax declaration presented by the petitioner was dated 1971, and there was no evidence of actual occupation of the lot prior to the application for registration.

ISSUES:

  1. Whether or not the subject lot is part of the alienable and disposable lands of the public domain.

  2. Whether or not the petitioner and his predecessors-in-interest have been in adverse possession of the subject lot for the required period.

RULING:

  1. The Court of Appeals reversed the decision of the trial court and held that the subject lot is part of the alienable and disposable lands of the public domain.

  2. The Court of Appeals found that petitioner failed to prove that he or his predecessors-in-interest have been in adverse possession of the subject lot in the required manner and for the required duration. Thus, the trial court erred in granting the application for registration of title over the subject lot.

PRINCIPLES:

  • The burden of proof rests on the applicant for land registration to prove that the land sought to be registered forms part of the alienable and disposable lands of the public domain.

  • To establish possession required by law for registration purposes, it must be shown that the applicant and his predecessors-in-interest have been in open, continuous, exclusive, and notorious possession and occupation of the land under a bona fide claim of ownership since June 12, 1945 or earlier.