Bohol v. Republic

Summary

The Provincial Government of Bohol sought registration of disputed property under Section 14(2) of P.D. 1529, claiming ownership through acquisitive prescription based on over thirty years of possession. The government's evidence consisted primarily of sporadic real property tax payments from 1962 to 1999. All three court levels denied the application, finding that irregular tax payments over decades do not constitute sufficient proof of the 'public, peaceful and uninterrupted possession in the concept of an owner' required under Civil Code provisions for acquiring ownership through prescription. The Supreme Court emphasized that more tangible evidence of actual possession is necessary beyond episodic tax payments. This case clarifies the evidentiary standards for proving acquisitive prescription in land registration proceedings, establishing that mere tax payments alone are insufficient to demonstrate the continuous possession required for ownership by prescription.