SAN MIGUEL CORPORATION VS.

COURT OF APPEALS, digested

Posted by Pius Morados on November 8, 2011

(GR # 57667, May 28, 1990) (Law on Natural Resources, Tax Declaration and Receipts)

FACTS: This is a petition for review on certiorari where petitioner San Miguel Corporation who
purchased Lot 684 from Silverio Perez, seeks the reversal of the decision of the Court of Appeals denying
its application for registration of the said land in view of its failure to show entitlement thereto.

The Solicitor General opposed and appealed the application contending that the land in question is part
of public domain and that petitioner being a private corporation is disqualified from holding alienable
lands of the public domain. In this case, petitioner claims that its predecessor-in-interest had open,
exclusive and undisputed possession of the land in question based on documentary evidence of tax
declarations and receipts, and testimonial evidence of vendor Silverio Perez.

ISSUE: Whether or not the evidence presented by the petitioner is sufficient to warrant a ruling that
petitioner and/or its predecessor-in-interest has a registrable right over Lot 684.

HELD: No, documentary evidence of tax declarations and receipts are not conclusive evidence of
ownership or right of possession over a piece of land but mere indicia of a claim of ownership. They only
become strong evidence of ownership of land acquired by prescription when accompanied by proof of
actual possession. Also, the testimony of vendor Silverio Perez as proof of actual possession is weak and
was not corroborated by other witnesses.