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REPUBLIC, v. APOLONIO BAUTISTA

FACTS:

Apolonio Bautista Jr. filed an application for the judicial confirmation of title over Lot 17078 of Cad. 547-D, Subic Cadastre. The property was acquired by Apolonio Sr. from Mario Jardin on February 15, 1971, and from Cornelia Villanueva on May 25, 1973. Apolonio Sr. had possessed and occupied the property since the time of acquisition until his death in 1987. After his death, Apolonio Jr. and his siblings executed an extra-judicial settlement of their father's estate, waiving their rights in favor of Apolonio Jr. The property was declared in Apolonio Jr.'s name under Tax Declaration No. 014-0432A of the Municipality of Subic, Zambales. Apolonio Jr. filed the application in October 1996 and testified that his father had been in actual possession of the property since 1969, and had paid taxes thereon. The Municipal Trial Court (MTC) granted Apolonio Jr.'s application, and the decision was affirmed by the Court of Appeals (CA). The Government appealed, arguing that Apolonio Jr.'s testimony was hearsay and his possession did not meet the requisite period as provided by law. The Supreme Court reversed the decision, holding that there was no sufficient evidence of possession "since June 12, 1945, or earlier," as required by law, and dismissed the application.

ISSUES:

  1. Whether Apolonio Bautista, Jr. was able to establish his lawful occupation of the land as owner in fee simple.

  2. Whether Apolonio Bautista, Jr.'s testimony on possession is hearsay and has no probative value.

  3. Whether the application for judicial confirmation of imperfect title complied with the requirement of possession since June 12, 1945 or earlier.

RULING:

  1. The Supreme Court held that the application for judicial confirmation of imperfect title must be dismissed for failure to comply with the requirement of possession since June 12, 1945 or earlier. Apolonio Bautista, Jr. failed to establish the requisite length of possession of the predecessors-in-interest of the applicant that would be tacked to his own. His personal testimony on possession was deemed hearsay and had no probative value. Furthermore, the possession and occupation of the property by Apolonio, Jr. and his predecessors-in-interest were not shown to have been "since June 12, 1945 or earlier." Therefore, the application for judicial confirmation of title was rejected.

PRINCIPLES:

  • The applicant for judicial confirmation of imperfect title must trace his possession of the subject land to June 12, 1945, or earlier. Any length of possession that does not comply with the requirement cannot support the application. (Public Land Act and Property Registration Decree)

  • Only the title of those who had possessed and occupied alienable and disposable lands of the public domain within the requisite period can be judicially confirmed. (Republic v. Naguit)

  • Hearsay evidence, even if admitted by the trial court, cannot be given any weight or value for purposes of judicial adjudication. (Rules of Court)