Republic vs. Maria Lee and IAC, G.R. No. 64818, May 13, 1991 (197
SCRA)

“failure to prove bonafide  claim t o land thr ough tacking poss

posses
ession
sion fr om Issue:
predecessor-in –interest to meet requirements provided by law”  

Whether or not the respondent is able to provide sufficient and substantial

Facts:  evidence as complying with the requirement of law for confirmation of her
ownership of the land in dispute?

Respondent filed before the RTC a registration of a parcel of land in her

favor which was opposed by the Dir. Of Lands on grounds that respondent Ruling: 
or her predecessor-in-interest acquired the land under any recognized
mode for acquisition of title; they have not been in open, continuous,
exclusive, notorious possession of the land in the concept of an owner for In is held that it is incumbent upon the respondent to prove that her
at least 30 years prior to the filing of application and the land in dispute is  predecessor-in-interest is the persons of Urbano Diaz and Bernarda
a public domain belonging to Republic of the Philippines. The court Vinluan have been in adverse, continuous, open, public, peaceful
rendered judgment in favor of respondents. Upon appeal by RP, it affirmed  possession in the concept of an owner for 20 years which she failed to
the lower court decision thus this appeal to the Supreme Court.  provide a clea r and convincing evidence to prove. Her bare allegations do
not constitute substantial proof. Respondent failed to comply with the
requirements of the law to confirm her title on the land applied for
Republic of the Phil. contends that respondent failed to prove by registration. Lower court decision was set aside.
conclusive evidence that she has ownership of the land by fee simple title
Underlying Principle: All lands not acquired from the government belong
and her testimony as to the ownership of her predecessor-in-interest is self
to the state as part of public domain.
serving after claiming that she obtained her Deed of Sale of the property
from Laureana Mataban and Sixto Espiritu who obtained their title from
the previous owners of the land, Urbano Diaz and Bernarda Vinluan. From
the time of filing the application of registration, the respondent was in
 possession of the land for 13 years but she sought to tack her possession
on the said land from her predecessor-in-interests who were in possession
of the land for 20 years. Conditions provided by Sec. 48 (b) of
Commonwealth Act No. 141 where one is under a bonafide claim of
acquisition of ownership through their predecessor-in-interest or by
themselves have been in open, continuous, exclusive and notorious
 possession and occupation of the agricultural l and in public domain for 30
years shall be entitled to a certificate of title.