Petitioner
Republic of the Philippines
Respondent
Pedro O. Enciso
Citation
G.R. No. 160145
Court
Supreme Court
Division
Second Division
Ponente
Chico-Nazario, J.
Decided
November 11, 2005

Summary

Pedro Enciso applied for registration of a 1,475-square meter residential lot in Masinloc, Zambales, claiming ownership through inheritance and continuous possession. The Republic opposed, arguing the land was not properly classified as alienable and disposable public domain land. The RTC and Court of Appeals granted the application, finding valid acquisition from the municipality through a chain of title. However, the Supreme Court reversed, holding that reclaimed public domain lands cannot be sold to private parties without legislative authorization, and that Enciso failed to prove the land was classified as alienable and disposable or establish the required possession since June 12, 1945. The case established important precedent regarding the inalienability of reclaimed public domain lands and the strict requirements for land registration under the Regalian doctrine.

Statutes applied

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By Intellegal Editorial Board · November 11, 2005

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