Republic of the Philippines v. Northern Cement Corporation

Summary

Northern Cement Corporation applied for original registration of a 58,617.96 square meter lot in Sison, Pangasinan under PD 1529, claiming ownership through a 1968 deed of sale. The RTC and CA granted the application, but the Supreme Court reversed, finding Northern Cement failed to prove the required possession by prescription under Section 14(2) of PD 1529. The Court ruled that intermittent tax payments over 32 years, testimonial conclusions without specific acts of possession, and minimal improvements (only cogon grass and unirrigated rice) were insufficient to establish open, continuous, exclusive and notorious possession in the concept of owner for the required 30-year period under Civil Code Articles 1137 and 1118. The case demonstrates the stringent evidentiary requirements for original land registration, emphasizing that actual possession and development, not mere tax declarations, are essential to prove ownership by prescription.