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    Republic v. Naguiat

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    Stephen Roy Argosino
    Celestina Naguiat applied to register title over four parcels of land that she claimed to have acquired through purchase. However, the Republic of Philippines opposed on the grounds that the lands were part of the public domain. Both the RTC and CA ruled in favor of Naguiat, finding she had possessed the lands for over 30 years. The Supreme Court reversed, ruling that the lands remained public unless reclassified by the government, and that possession alone could not convert public land to private land. As Naguiat did not present certification of reclassification, the lands were still considered public domain and not subject to private ownership or registration.

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    Republic v. Naguiat

    Uploaded by

    Stephen Roy Argosino
    50 views2 pages
    Celestina Naguiat applied to register title over four parcels of land that she claimed to have acquired through purchase. However, the Republic of Philippines opposed on the grounds that the lands were part of the public domain. Both the RTC and CA ruled in favor of Naguiat, finding she had possessed the lands for over 30 years. The Supreme Court reversed, ruling that the lands remained public unless reclassified by the government, and that possession alone could not convert public land to private land. As Naguiat did not present certification of reclassification, the lands were still considered public domain and not subject to private ownership or registration.

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    Celestina Naguiat applied to register title over four parcels of land that she claimed to have acquired through purchase. However, the Republic of Philippines opposed on the grounds that the lands were part of the public domain. Both the RTC and CA ruled in favor of Naguiat, finding she had possessed the lands for over 30 years. The Supreme Court reversed, ruling that the lands remained public unless reclassified by the government, and that possession alone could not convert public land to private land. As Naguiat did not present certification of reclassification, the lands were still considered public domain and not subject to private ownership or registration.

    Copyright:

    © All Rights Reserved
    Download as DOCX, PDF, TXT or read online from Scribd
    Download as docx, pdf, or txt
    50 views2 pages

    Republic v. Naguiat

    Uploaded by

    Stephen Roy Argosino
    Celestina Naguiat applied to register title over four parcels of land that she claimed to have acquired through purchase. However, the Republic of Philippines opposed on the grounds that the lands were part of the public domain. Both the RTC and CA ruled in favor of Naguiat, finding she had possessed the lands for over 30 years. The Supreme Court reversed, ruling that the lands remained public unless reclassified by the government, and that possession alone could not convert public land to private land. As Naguiat did not present certification of reclassification, the lands were still considered public domain and not subject to private ownership or registration.

    Copyright:

    © All Rights Reserved
    Download as DOCX, PDF, TXT or read online from Scribd
    Download as docx, pdf, or txt
    of 2

    Digest by: Stephen Roy F.

    Argosino

    G.R. No. 134209. January 24, 2006


    REPUBLIC OF THE PHILIPPINES, petitioner, vs. CELESTINA NAGUIAT, respondent

    GARCIA, J.

    ANTECEDENTS OF THE CASE

    On December 29, 1989, respondent Celestina Naguiat applied before


    the RTC of Zambales registration of title of four (4) parcels of land. Respondent
    alleges that she is the owner of said parcels of land having acquired them by
    purchase from the LID Corporation which likewise acquired the same from
    Demetria Claderon and their predecessors-in-interest who have been in
    possession thereof for more than thirty (30) years.

    Petitioner Republic of the Philippines filed an opposition on the grounds


    that the respondent was not in open, continuous, exclusive and notorious
    possession of the subject parcels of land since June 12, 1945 or prior thereto
    and that the lands in question are part of the public domain and not subject
    to private appropriation.

    RTC Ruling: Ruled in favor of Celestina Naguiat adjudicating the parcels


    of land in her favor.

    CA Ruling: Affirmed the ruling of the RTC finding a registrable title for
    respondent on the ground that respondent and her predecessors-in-interest
    are in open, continuous, exclusive and notorious possession of the property for
    more than 30 years and that upon the completion of the requisite period of
    possession, the lands in question cease to be public land and become private
    property.

    ISSUE/S OF THE CASE

    Whether or not the areas in question have ceased to have the status of forest
    or other inalienable lands of the public domain.

    COURTS’ RULING

    No. Respondent never presented the required certification from proper


    government agency or official proclamation reclassifying the land applied for
    as alienable and disposable. Land classification or reclassification cannot be
    assumed.

    Submission of tax receipts are not sufficient proof to overcome the


    presumption that the land sought to be registered forms part of the public
    domain. Under Section 2, Article XII of the Constitution, all lands of public
    domain belong to the State. Public lands which have not been reclassified as
    alienable agricultural land by the State remain part of the public domain.
    Declassificaiton of forest and mineral lands and their conversion into alienable
    and disposable lands need an express and positive act from the government.

    The issue of whether or not respondent have been in open, continuous,


    exclusive and notorious possession of the parcels of land in question is of no
    moment. For, unclassified land cannot be acquired by adverse occupation or
    possession. Occupation thereof in the concept of an owner, however long,
    cannot ripen into private ownership and be registered as title.

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