Republic of the Philippines v. Science Park of the Philippines

Summary

Science Park of the Philippines, Inc. applied for original registration of title over a 5,255 square meter lot in Malvar, Batangas under Section 14(1) of PD 1529, claiming possession since June 12, 1945 through predecessors-in-interest. The MCTC and Court of Appeals granted the application, finding sufficient evidence of the required possession. However, the Supreme Court reversed, applying stare decisis from a similar 2018 case involving the same parties. The Court found that respondent failed to prove the requisite open, continuous, exclusive, and notorious possession since June 12, 1945, noting that the witness testimony was insufficient (events recalled from age 7), the earliest tax declaration was from 1955 (not 1945), and the evidence amounted to mere casual cultivation rather than the exclusive dominion required by law. The case demonstrates the strict evidentiary requirements for land registration under Section 14(1) of the Property Registration Decree.