Batungbacal v. Republic

Summary

The Supreme Court denied petitioners' appeal seeking judicial confirmation of title over contested land through acquisitive prescription. Petitioners claimed ownership based on alleged continuous possession since 1945 or earlier. The Court of Appeals found insufficient proof of the required possession elements. The Supreme Court affirmed, ruling that even if the property was declared alienable and disposable, acquisitive prescription cannot run against the State without a formal declaration from Congress or Presidential Proclamation converting the public land to patrimonial property. The property remained outside the commerce of man, making the petitioners' physical possession legally ineffective for acquiring ownership. The CENRO certification was insufficient to establish the required conversion from public to patrimonial property.