TL;DR

The Supreme Court denied the Buyco brothers’ petition to register a large parcel of land because they failed to provide sufficient evidence proving the land’s alienable and disposable status. To successfully register land under the Torrens system, applicants must present both a certified copy of the original land classification approved by the DENR Secretary and a certificate of land classification status issued by CENRO or PENRO. This decision reinforces the strict requirements for land registration, emphasizing the need for conclusive proof of land classification to prevent invalid claims on public domain lands. This ensures the integrity of the Torrens system and protects against improper land acquisition.

Second Attempt Denied: When Land Classification Proof Falls Short

This case revolves around Samuel and Edgar Buyco’s second attempt to register a large parcel of land in Romblon, following a previous denial due to insufficient proof that the land was alienable and disposable. The central legal question is whether the evidence presented in the second application adequately addressed the deficiencies identified in the first case, specifically regarding the land’s classification.

The Buyco brothers sought to register Lot 1, Psu-127238, covering approximately 3,194,788 square meters in Romblon. Their initial application was rejected by the Supreme Court in G.R. No. 91189 due to the lack of evidence demonstrating that the Subject Land was alienable and disposable. The Court found that the brothers did not offer any proof of the land’s classification, which is a crucial requirement for land registration. The land was pasture land and grazing lands are not alienable under Section 1, Article XIII of the 1935 Constitution and sections 8, 10 and 11 of Article XIV of the 1973 Constitution.

In their second attempt, the Buycos presented several documents, including a sketch plan (Exhibit “DD”) with a certification indicating the land was within the alienable and disposable zone, and a report (Exhibit “OO”) from the Community Environment and Natural Resources Office (CENRO) stating the same. Romulae Gadaoni, a Land Management Officer III, testified that her ocular inspection of the property confirmed its use as a ranch and its location within the alienable and disposable zone. Despite this, the Court found these proofs insufficient.

The Supreme Court, in its analysis, cited the cases of In Re: Application for Land Registration Suprema T. Dumo v. Republic of the Philippines and Republic of the Philippines v. T.A.N. Properties, Inc. to reiterate the strict evidentiary requirements for proving land classification. These cases emphasize that TWO specific documents must be presented: a copy of the original classification approved by the DENR Secretary, certified by the legal custodian of official records, and a certificate of land classification status issued by CENRO or PENRO, based on the DENR Secretary’s approved classification. This stringent requirement is necessary to ensure the integrity of the land registration process.

Building on this principle, the Court noted that a CENRO or PENRO certification alone is insufficient. The classification of land must be proven through the original classification approved by the DENR Secretary or the President. This requirement underscores the importance of official documentation and the need to trace the land’s classification back to its original source. Therefore, the proofs presented by the Buycos, mainly the CENRO certification, fell short of the required standard.

“[A] CENRO or PENRO certification is not enough to prove the alienable and disposable nature of the property sought to be registered because the only way to prove the classification of the land is through the original classification approved by the DENR Secretary or the President himself.”

Consequently, the Supreme Court denied the petition, affirming the Court of Appeals’ decision to reverse the trial court’s grant of land registration. The Court emphasized that without proper documentation tracing back to the DENR Secretary’s approval, the land’s alienable and disposable status could not be sufficiently established. This ruling reinforces the need for meticulous compliance with land registration requirements to prevent invalid claims and protect public domain lands.

This approach contrasts with a more lenient interpretation, which might have considered the CENRO certification as sufficient evidence, particularly given the passage of time and potential difficulties in obtaining older records. However, the Court’s strict adherence to the documentary requirements highlights its commitment to maintaining the integrity of the Torrens system and ensuring that only legitimately alienable lands are registered. Thus, the failure to meet these stringent requirements proved fatal to the Buycos’ application.

FAQs

In conclusion, this case underscores the importance of adhering to strict evidentiary standards when seeking to register land under the Torrens system. The requirement for original documentation approved by the DENR Secretary ensures that only legitimately alienable lands are brought within the system, protecting the integrity of land titles and preventing invalid claims.

For inquiries regarding the application of this ruling to specific circumstances, please contact Atty. Gabriel Ablola through gaboogle.com or via email at connect@gaboogle.com.

Disclaimer: This analysis is provided for informational purposes only and does not constitute legal advice. For specific legal guidance tailored to your situation, please consult with a qualified attorney.
Source: Samuel and Edgar Buyco v. Republic, G.R. No. 197733, August 29, 2018