FACTS

Respondent Remman Enterprises filed with the Regional Trial Court of

Pasig City an application for judicial confirmation of title over two parcels of land

located in Barangay Napindan, Taguig. It purchased the respective lands from

Conrado Salvador and Bella Mijares.

Petitioner Republic of the Philippines opposed the application on the ground

that Remman Enterprises failed to prove compliance with the first requisite of Sec.

14(1) of PD 1529, which requires that the land sought for judicial titling should be

disposable and alienable.

To prove that the subject properties form part of the alienable and disposable

lands of the public domain, Remman Enterprises presented copies of two

certifications issued by DENR Senior Forest Management Specialist Corazon

Calamno, attesting that the said parcels of land form part of the alienable and

disposable lands of the public domain “under Project No. 27-B of Taguig, Metro

Manila as per LC Map 2623, approved on January 3, 1968.”

The RTC ruled in favor of Remman Enterprises, finding that the respondent

sufficiently proved the subject properties as alienable and disposable lands.

The Republic petitioned to the Court of Appeals. The CA, however, agreed

with the RTC, ruling that the presentation of copies of the certifications issued by

the DENR attested to the status of the lands as alienable and disposable, of which

the Republic did not dispute.

Hence, the Republic’s petition before the Supreme Court.

ISSUE

Whether or not copies of DENR certifications that attest to the status of the

land as being alienable and disposable are sufficient.

RULING

No, the said certifications presented by Remman Enterprises are insufficient

to prove that the subject properties are alienable and disposable.

In addition to the certification issued by the proper government agency that a

parcel of land is alienable and disposable, applicants for land registration must

prove that the DENR Secretary had approved the land classification and released

the land of public domain as alienable and disposable. They must present a copy of

the original classification approved by the DENR Secretary and certified as true

copy by the legal custodian of the records.

Having failed to prove that the subject properties form part of the alienable

and disposable lands of the public domain, Remman Enterprises’ application for

registration should be denied.

The Supreme Court, thus, granted the Republic’s petition.