View full case

REPUBLIC v. CESAR P. RAYOS DEL SOL

FACTS:

This case involves a petition for land registration filed by the respondent siblings for Lot 8173-A in Barangay Ligid Tipas, Taguig, Metro Manila. They claimed to have inherited the lot from their father and grandfather and asserted possession and occupation of the land since the 1930s. The lot was subdivided into four parcels in 2004. The Republic of the Philippines purchased a portion of the lot in 2006. Witnesses testified to the possession and cultivation of the lot by the respondents and their predecessors. Various documents, including an extrajudicial settlement, a deed of absolute sale, a conversion subdivision plan, and tax declarations were presented as evidence. The Regional Trial Court ruled in favor of the respondents, ordering the issuance of the decree of registration and certificate of title in their names.

The Republic of the Philippines filed an appeal against the decision of the Court of Appeals (CA), which dismissed their appeal. The respondents presented evidence of open, exclusive, continuous, and notorious possession and occupation of the land. Witnesses testified that their possession began in the 1930s and continued until the present. The CA considered the tax declarations as proof of the respondents' claim of title and noted that the deed of absolute sale acknowledged their ownership of the land. The Republic argued that the respondents failed to prove the required period of occupation and that the deed of sale referred to a different lot.

ISSUES:

  1. Whether the respondents' possession and occupation of the subject land since June 12, 1945, or earlier, have been sufficiently proven.

  2. Whether the testimonial evidence presented by the respondents supports their claim of ownership and possession.

RULING:

  1. Yes. The Court finds that the respondents' possession and occupation of the subject land since June 12, 1945, or earlier, have been sufficiently proven. The testimonial evidence provided by the respondents, including their own testimony and that of their witnesses, establishes their open, continuous, exclusive, and notorious possession of the land in the concept of an owner.

  2. Yes. The testimonial evidence presented by the respondents supports their claim of ownership and possession. This evidence shows that the respondents and their predecessors-in-interest have occupied and possessed the subject land since June 12, 1945, or earlier, in an open, continuous, exclusive, and notorious manner, under a bona fide claim of ownership.

PRINCIPLES:

  • To qualify for registration of title to land based on possession, the applicant must prove his claim by clear and convincing evidence and should not rely on the absence or weakness of evidence of the oppositors.

  • Tax declarations have probative value in land registration proceedings and may serve as sufficient basis for inferring possession. While not conclusive evidence of ownership, tax declarations coupled with actual possession constitute evidence of great weight and can be the basis for a claim of ownership through prescription.

  • Compliance with Section 14(1) of P.D. No. 1529 requires the applicant to show open, continuous, exclusive, and notorious possession and occupation of the land under a bona fide claim of ownership since June 12, 1945, or earlier. However, the exact date of the tax declaration does not necessarily determine compliance if the evidence as a whole shows that the applicant has been in possession prior to June 12, 1945.

  • In order to support a registration of land under the Torrens system, the applicant must prove open, continuous, exclusive, and notorious possession of the property in the concept of an owner since June 12, 1945, or earlier.

  • Testimonial evidence, when credible and consistent, may be sufficient to prove the possession and occupation of land in support of an application for registration.

  • Open, continuous, exclusive, and notorious possession and occupation are essential elements to support a claim for original registration of land.

  • Documentary and testimonial evidence can be used to establish possession and occupation of land.

  • The absence of evidence presented by the opposing party to disprove or contradict the claims of the applicant is significant in evaluating the sufficiency of the evidence.