Yu Chang v. Republic

G.R. No. 171726 (February 23, 2011)

Supreme Court denied Yu Changs' land title; failed to prove land was alienable before 1986.

Facts:

The case involves a petition for review on certiorari filed by Vicente Yu Chang and Soledad Yu Chang against the Republic of the Philippines concerning the registration of title over two parcels of land, Lots 2199 and 2200 of Cad. 291, Pili Cadastre. The petitioners' father, L. Yu Chang, entered into an Agreement to Exchange Real Property with the Municipality of Pili on March 22, 1949, wherein he transferred his 400-square-meter residential lot in exchange for a similar-sized lot in San Juan, Pili. Following this exchange, L. Yu Chang and his family took possession of the new property, constructed a residential house and a gasoline station, and declared the property under their name for taxation purposes, paying real property taxes from 1951 to 1976.

Upon L. Yu Chang's death in 1976, his wife and seven children inherited the property. In 1978, five of L. Yu Chang's children executed a Deed of Transfer and Renunciation of their rights over the property in favor of Vicente and Soledad Yu Chang. The petitioners subsequently had the property surveyed and subdivided into two lots, which they declared for taxation purposes.

On February 21, 1997, Soledad Yu Chang filed a petition for registration of title over the two lots, claiming that they and their predecessors had been in actual, physical, and exclusive possession of the land for over 100 years. The Republic, through the Office of the Solicitor General, opposed the application, arguing that the petitioners failed to demonstrate the necessary possession and that the land was classified as public domain and not subject to private appropriation.

The Regional Trial Court initially granted the petitioners' application, confirming their imperfect title over the lots. However, the Republic appealed this decision to the Court of Appeals, which reversed the trial court's ruling, leading to the current petition for review.

Legal Issues:

  1. Whether the petitioners established that the subject lots are alienable and disposable lands of the public domain.
  2. Whether the petitioners demonstrated open, continuous, exclusive, and notorious possession of the lots since June 12, 1945, or earlier.

Arguments:

  • Petitioners' Arguments:

    • The petitioners contended that the subject properties could no longer be classified as forest land due to the presence of buildings and structures, asserting that they had been in continuous possession of the land since 1949.
    • They argued that the original owner, the Municipality of Pili, had established the land as part of its municipal grounds, and thus, their possession should be recognized.
  • Republic's Arguments:

    • The Republic maintained that the petitioners failed to prove their possession of the land for the required period and that the land was classified as public forest land, which could not be subject to private appropriation.
    • The Republic emphasized that the lots were only declared alienable and disposable on October 30, 1986, and that prior possession of forest land does not count towards the requirements for registration.

Court's Decision and Legal Reasoning:

The Supreme Court denied the petition for lack of merit, affirming the Court of Appeals' decision. The Court held that the petitioners did not provide sufficient evidence to establish that the lots were alienable and disposable lands of the public domain. It reiterated that under Section 48(b) of the Public Land Act, applicants must prove that the land is alienable and that they have been in open, continuous, exclusive, and notorious possession since June 12, 1945.

The Court emphasized that mere possession of land classified as forest land does not equate to ownership or the right to register the title. It cited the precedent that possession of forest land prior to its official declassification as alienable and disposable is ineffective for purposes of confirming imperfect title. The Court also noted that the presence of structures on the land does not change its legal classification without a formal government declaration.

Significant Legal Principles Established:

  1. The classification of land as forest land remains until an official government act declassifies it as alienable and disposable.
  2. Possession of forest land does not count towards the period required for confirmation of imperfect title until the land is declared alienable and disposable.
  3. The burden of proof lies with the applicants to establish that the land is not part of the public domain and that they have met the legal requirements for registration.