PRESIDENTIAL DECREE NO.

1529
AMENDING AND CODIFYING THE LAWS RELATIVE TO REGISTRATION OF PROPERTY AND FOR OTHER
PURPOSES

SECTION 47. Registered Land Not Subject to Prescription. — No title to registered land in derogation of
the title of the registered owner shall be acquired by prescription or adverse possession

RAMOS VS COURT OF APPEALS

GR. NO. 111027

FACTS:

• On March 14, 1939, Pedro Tolentino, claiming absolute ownership over Lot Nos. 572 and 579 of
the Gattaran cadastre in Lapogan, Gattaran, Cagayan, separately sold said lots to petitioners,
the spouses Bernardino Ramos and Rosalia Oli, in consideration of the amount of eighty pesos
(P80.00) for each sale.
• petitioners instituted on January 8, 1976 an action for reconveyance with damages alleging that
while they were "in open, public, adverse, peaceful and continuous possession" of the subject
lots "in good faith and with just title, for not less than 50 years, personally and through their
predecessors-in-interest," they were surprised to discover in November 1975, that decrees of
registration covering Lot Nos. 572 and 579 were already issued on January 7, 1940.
• They complained further that the subsequent issuance by the Register of Deeds of Cagayan on
March 1941 respectively, in favor of Lucia Bautista since the latter allegedly neither laid claim
of ownership nor took possession of them, either personally or through another.
• The petitioners concluded that the original certificates of title as well as Transfer Certificates
of Title obtained by private respondent Rodolfo Bautista who adjudicated unto himself said lots
on September 20, 1975, as sole heir of Lucia Bautista were null and void. On the theory that they
already acquired the subject lots by acquisitive prescription, petitioners demanded their
return but private respondents refused to do so, hence, compelling them to file a complaint
for reconveyance with damages.
• Private respondents claimed absolute ownership of the lots. They alleged while the records of
the Bureau of Lands showed that during the cadastral survey in Gattaran in 1932, Pedro Tolentino
was a claimant over lands in the cadastre, the same was only with respect to Lot No. 1399 which
was eventually titled under his name as OCT No. 16110. It just happened that Lot No. 1399 was
adjacent to Lot No. 572, a portion of which was occupied by petitioners upon the tolerance of
the original registrant Lucia Bautista.
• Respondents maintained that the action for reconveyance brought by the petitioners is
tantamount to a collateral attack to the decrees of registration while asserting the indefeasible
of the Torrens Title.
• The trial court dismissed petitioners' complaint underscoring the fact that during the cadastral
proceedings in 1940, Bernardino Ramos did not file an answer for the two lots although he was
allegedly the claimant and possessor thereof under the deeds of sale executed by Pedro Tolentino
in his favor on March 14, 1939.
• Since it was only Lucia Bautista who filed an answer and who appeared to be the lawful claimant
in the proceedings, she was therefore issued original certificates of title for the subject lots. The
trial court presumed that everyone was notified about the proceedings inasmuch as cadastral
proceedings are in rem.
• The petitioner has 1 year from the issuance of the decree to file for the reopening of the
proceeding on ground of fraud but he did not do so. Latches against him have set in for filing
 the action for reconveyance 36 years after. The court of appeals upheld the decision of the
lower court hence this petition before the SC.

ISSUE:

WON the registered title of the respondents can be attacked by the petitioners

HELD:

• Petitioners anchor their claim for ownership over the parcels of land by virtue of the deed
of sale executed between them and Pedro Tolentino. However, they failed to present
evidence according to the forms required by law.
• The deed of sale was apparently lost by a fire from their counsel’s office and in lieu thereof they
presented a certification from a notary public who was their other lawyer attesting to the
authenticity of the certified true copy of the deed of sale. The certification however does not
meet the requirement of law provided in section 20 of Rule 132 where before a private document
be received as authentic it must be proved by anyone who witness the execution of the document
or there is genuineness on the signature of the maker presented in evidence. They failed to
present any witness to the execution of said document and they could not demonstrate the
genuineness of the signature from the document as it does not bear any signature of the
maker. Furthermore, even if there is authenticity to the document, the basic civil law principle
of relativity of contract operates and it cannot bind third party like Lucia. This basic principle
applies even if the sales were supposedly concluded at a time prior to the operation of the
Torrens system of land registration over the properties involved. When the properties were
eventually titled in favor of Lucia Bautista, the sale between Pedro Tolentino and petitioners
could not have affected Lucia Bautista and her successor-in-interest because the pertinent law
• Failure to register the contract of sale to the said lot, the sale was merely binding between
the petitioner and the vendor. Petitioners presented evidence of mortgage of the property
but those did not conform to the form required by law. The instrument did not sufficiently
describe the property of the mortgage therefore it would be difficult for the court to assume
that the property mortgage was the same as the subject of dispute. Their claim of possession
of not less than 50 years on the property can be construed as a bare claim and it is upon the
petitioner to have the burden of proving their claim of possession to the lot which they failed
to prove in court.
• Their claim of fraud was not substantiated. Under the law, an action for reconveyance on ground
of fraud prescribed in 4 years which is counted from the issuance of the registration of title to
Lucia Bautista because the registration served as a constructive notice to the whole world. On
one hand, an action based on implied or constructive trust prescribes in ten (10) years. This
means that petitioners should have enforced the trust within ten (10) years from the time of
its creation or upon the alleged fraudulent registration of the property. But the petitioners
failed to avail of any of the aforementioned remedies within the prescribed periods. Private
respondents have in their favor the law that protects holders of title under the Torrens System
of land registration. Petition was denied.

NOTES:

• LAND TITLES AND DEEDS; CADASTRAL ACT; ORIGINAL CERTIFICATES OF TITLE ISSUED THEREUNDER
SHALL HAVE SAME EFFECT AS CERTIFICATES ISSUED UNDER LAND REGISTRATION ACT. — Under the
Cadastral Act, the original certificates of title issued to the original registrant, shall have the
same effect as certificates of title granted on application for registration of land under the Land
Registration Act, because "no title to registered land in derogation to that of the registered
 owner shall be acquired by prescription or adverse possession." Pedro Tolentino and
petitioners, as the former's alleged successors-in-interest, have therefore no valid claim of
ownership over the property, particularly since petitioners simply failed to substantiate the
nature and extent of Tolentino's rights and interests over the lots. Such being the case, the
conveyances.
• Section 38 of the Land Registration Act provides that a decree of registration duly issued is
subject "to the right of any person deprived of land or of any estate or interest therein by decree
of registration obtained by fraud to file in the competent Court of First Instance (now the
Regional Trial Court) a petition for review within one year after entry of the decree, provided
no innocent purchaser for value has acquired an interest." The same law provides that upon the
expiration of the term of one year, "every decree or certificate of title . . . shall be
imprescriptible."

CIVIL CODE

ARTICLE 494. No co-owner shall be obliged to remain in the co-ownership. Each co-owner may demand
at any time the partition of the thing owned in common, insofar as his share is concerned. aisa dc

Nevertheless, an agreement to keep the thing undivided for a certain period of time, not exceeding ten
years, shall be valid. This term may be extended by a new agreement.

A donor or testator may prohibit partition for a period which shall not exceed twenty years.

Neither shall there be any partition when it is prohibited by law.

No prescription shall run in favor of a co-owner or co-heir against his co-owners or co-heirs so long as he
expressly or impliedly recognizes the co-ownership. (400a)

CENIZA VS COURT OF APPEALS

GR.NO. L-46345
FACTS:

• On June 14, 1967, the petitioners filed against private respondents, an action in the Court of
First Instance of Cebu for recovery of their title to Lots Nos. 627-B and 627-C situated in
Casuntingan, Mandaue, Cebu (now Mandaue City), which originally formed part of "Hacienda de
Mandaue" of the Seminario de San Carlos de Cebu.
• the private respondents are the descendants of his sister, Sofia Ceniza. Sofia Ceniza was
childless but she had an adopted daughter named Flaviana Ceniza, who begot a daughter named
Marced Ceniza and who in turn had a daughter named Marcelina Ceniza who married Vicente
Dabon. Private respondents are the children of this marriage and they are the great-great-
grandchildren of Sofia Ceniza.
• Petitioners are the descendants of Manuel Ceniza. Manuel Ceniza had an only son, Pablo, who
had two sons, Santiago and Jose Ceniza. Petitioners Restituto and Jesus Ceniza and a certain
Nemesia Ceniza-Albina are their children and the great-grandchildren of Manuel Ceniza.
• The records disclose that when Hacienda de Mandaue was subdivided for resale to the
occupants in 1929, Jose Ceniza and Vicente Dabon, who were residing in the hacienda, jointly
purchased Lot 627 on installment basis and they agreed, for convenience, to have the land
registered in the name of Dabon. Jose Ceniza, Vicente Dabon, and their heirs have possessed
their respective portions of the land, declared the same for taxation, paid real estate taxes on
their respective shares, and made their respective installment payments to the Seminario de San
Carlos de Cebu.
 • On November 4, 1961, a private land surveyor, Espiritu Bunagan, on the request of Jacinta Dabon
and Restituto Ceniza who jointly defrayed the cost, divided Lot 627 into three parts.
• The present controversy arose because the private respondents refused to convey Lots Nos. 627-
B and 627-C to the petitioners. They claimed that their predecessor-in-interest, Vicente
Dabon, was the sole and exclusive owner of Lot 627, by purchase from the Seminario de San
Carlos de Cebu. In their answer to the petitioners' complaint for reconveyance in June 1967,
they alleged that the petitioners' right of action had already prescribed.
• On August 31, 1970, the trial court rendered judgment for the petitioners. Finding that there
existed a co-ownership among the parties, it ordered the private respondents to execute deeds
of conveyance of Lots Nos. 627-B and 627-C in favor of the plaintiffs, Restituto and Jesus Ceniza,
respectively
• On appeal by the defendants (now private respondents) the Court of Appeals on October 29,
1976, reversed that decision of the trial court. It ruled that the petitioners' right of action had
prescribed after the lapse of 20 years from the date of registration of the land on February 8,
1939 in Vicente Dabon's name. The petitioners have appealed to this Court by a petition for
review

ISSUE:

WON the registration of the title of the land in the name of one of the co-owners constituted a
repudiation of the coownership for purposes of acquisitive prescription.

HELD: We find merit in the petition for review.

• Trial court correctly ruled that since a trust relation and co-ownership were proven to exist
between the predecessors-in-interest of both petitioners and private respondents, prescription
did not run in favor of Dabon's heirs except from the time that they repudiated the co-ownership
and made the repudiation known to the other coowners, Restituto and Jesus Ceniza.
Paragraph 5 of Article 494 of the Civil Code provides —
"No prescription shall run in favor of a co-owner or co-heir against his co-
ownersor co-heirs so long as he expressly or impliedly recognizes the co-
ownership."
• The registration of Lot No. 627 in the name of Vicente Dabon created a trust in favor of his co-
owner Jose Ceniza, and the latter's heirs. The petitioners co-owners continue to possess their
respective shares of Lot 627 and they have been paying the realty taxes thereon. Restituto's
house stands on his portion of the Land. Assuming that the private respondents' rejection of the
subdivision plan for the partition of the land was an act of repudiation of the co-ownership,
prescription had not yet set in when the petitioners instituted the present action for
reconveyance
• since the statutory period of limitation within which to file an action for reconveyance, after the
defendants had repudiated the co-ownership in 1961, had not yet run its course when the
petitioners filed said action in 1967, the action was not barred by prescription.
 HEIRS OF FLORES RESTAR VS HEIRS OF DOLORES CICHON
GR. NO. 161720

FACTS:

• In 1935, Emilio Restar (Restar) died intestate, leaving eight (8) children-compulsory heirs,
namely: Flores Restar, Dolores Restar-Cichon, Perpetua Restar-Sta. Maria, Paciencia Restar-
Manares, Dominica Restar-Relojero, Policarpio Restar, Maria Restar-Rose and Adolfo Restar.
• In 1960, Restar's eldest child, Flores, on the basis of a July 12, 1959 Joint Affidavit he
executed with one Helen Restar, caused the cancellation of Tax Declaration No. 6696 in
Restar's name covering a 5,918 square meter parcel of land, Lot 3177 (the lot), located at
Barangay Carugdog, Lezo, Aklan which was among the properties left by Restar, and the issuance
of Tax Declaration No. 11134 in his name. Flores died on June 10, 1989. On November 5, 1998,
the co-heirs of Flores discovered the cancellation of Restar's Tax Declaration No. 6696 and the
issuance in lieu thereof of Tax Declaration No. 11134 in his name.
• On January 21, 1999, the heirs of Flores' sisters Dolores R. Cichon, Perpetua Sta. Maria, and Maria
Rose together with Flores' surviving sisters Dominica Restar-Relojero and Paciencia Restar-
Manares, filed a Complaint against Flores' heirs for "partition [of the lot], declaration of nullity
of documents, ownership with damages and preliminary injunction" before the Regional Trial
Court (RTC) of Aklan.
• The plaintiffs, herein respondents, alleged that, during the lifetime of Flores, they were given
their shares of palay from the lot and even after Flores death up to 1991; after Flores' death in
1989, his widow Esmenia appealed to them to allow her to hold on to the lot to finance the
education of her children, to which they (the plaintiffs) agreed on the condition that after
the children had finished their education, it would be divided into eight (8) equal parts; and
upon their demand for partition of the lot, the defendants Heirs of Flores refused, they
claiming that they were the lawful owners thereof as they had inherited it from Flores.
• Heirs of Flores claimed that they had been in possession of the lot in the concept of owner
for more than thirty (30) years and have been paying realty taxes since time immemorial.
And they denied having shared with the plaintiffs the produce of the lot or that upon Flores'
death in 1989, Esmenia requested the plaintiffs to allow her to hold on to it to finance her
children's education, they contending that by 1977, the children had already finished their
respective courses
• The Heirs of Flores further claimed that after World War II and under the "new Tax Declaration
in 1945," Flores caused the transfer of parcels of ricelands situated in Carugdog, Lezo, Aklan
to his siblings as their shares from the estate of their father Restar; and an extra-judicial
partition was subsequently executed on September 28, 1973 by Restar's heirs, which was
notarized, dividing and apportioning among themselves four (4) parcels of land.
• As for the defendant Policarpio Restar, he in his Amended Answer acknowledged Flores as the
owner of the lot but claimed that a portion of it, 1,315 square meters, was sold to him as
shown by a Deed of Absolute Sale dated May 14, 1981. He thus prayed that, among other
things, an order for the partition of the lot among Restar's heirs be issued excluding, however,
that portion sold to him by Flores.
• The RTC of Kalibo, Aklan held that Flores and his heirs had performed acts sufficient to
constitute repudiation of the co-ownership, concluded that they had acquired the lot by
prescription. The Court of Appeals reversed the decision finding that there was no adequate
notice by Flores to his co-heirs of the repudiation of the co-ownership and neither was there a
categorical assertion by the defendants of their exclusive right to the entire lot that barred the
plaintiffs’ claim of ownership.
ISSUE:

WON Heirs of Flores acquired ownership over the lot by extraordinary prescription

HELD: Appellate court held in the negative.

• The action to demand partition of a co-owned property does not prescribe, a co-owner may
acquire ownership thereof by prescription where there exists a clear repudiation of the co-
ownership, and the co-owners are apprised of the claim of adverse and exclusive ownership.
• Acquisitive prescription of dominion and other real rights may be ordinary or extraordinary.
Ordinary acquisitive prescription requires possession of things in good faith and with just title
for a period of ten years. Without good faith and just title, acquisitive prescription can only be
extraordinary in character which requires uninterrupted adverse possession for thirty years.
• When Restar died in 1935, his eight children became pro indiviso co-owners of the lot by intestate
succession. Heirs of Chichon never possessed the lot, however, much less asserted their claim
thereto until January 21, 1999 when they filed the complaint for partition subject of the
present petition. In contrast, Flores took possession of the lot after Restar’s death and exercised
acts of dominion thereon — tilling and cultivating the land, introducing improvements, and
enjoying the produce thereof. Flores’ possession thus ripened into ownership through
acquisitive prescription after the lapse of thirty years in accordance with the earlier quoted
Article 1137 of the New Civil Code.
• Indeed, the following acts of Flores show possession adverse to his co-heirs: the cancellation of
the tax declaration certificate in the name of Restar and securing another in his name; the
execution of a Joint Affidavit stating that he is the owner and possessor thereof to the exclusion
of respondents; payment of real estate tax and irrigation fees without respondents having ever
contributed any share therein; and continued enjoyment of the property and its produce to the
exclusion of respondents. And Flores’ adverse possession was continued by his heirs.
• The trial court’s finding and conclusion that Flores and his heirs had for more than 38 years
possessed the land in open, adverse and continuous possession in the concept of owner —
which length of possession had never been questioned, rebutted or disputed by any of the
heirs of Cichon, being thus duly supported by substantial evidence, he and his heirs have
become owner of the lot by extraordinary prescription. It is unfortunate that respondents
slept on their rights. Dura lex sed lex.
 PD 1529, Section 14 (4)

SECTION 14. Who May Apply. — The following persons may file in the proper Court of First Instance an
application for registration of title to land, whether personally or through their duly authorized
representatives:

(1) Those who by themselves or through their predecessors-in-interest have been in open, continuous,
exclusive and notorious possession and occupation of alienable and disposable lands of the public domain
under a bona fide claim of ownership since June 12, 1945, or earlier.

(2) Those who have acquired ownership of private lands by prescription under the provisions of existing
laws.

(3) Those who have acquired ownership of private lands or abandoned river beds by right of accession or
accretion under the existing laws.

(4) Those who have acquired ownership of land in any other manner provided for by law.

Where the land is owned in common, all the co-owners shall file the application jointly.

Where the land has been sold under pacto de retro, the vendor a retro may file an application for the
original registration of the land, provided, however, that should the period for redemption expire during
the pendency of the registration proceedings and ownership to the property consolidated in the vendee
a retro, the latter shall be substituted for the applicant and may continue the proceedings

G.R. No. 133250. July 9, 2002.

Chavez, vs. Public Estates Authority and Amari Coastal Bay Development Corp.
FACTS:

• The petition seeks to compel the Public Estates Authority (PEA) to disclose all facts on PEA's then
on-going renegotiations with Amari Coastal Bay and Development Corporation (AMARI) to reclaim
portions of Manila Bay. The petition further seeks to enjoin PEA from signing a new agreement
with AMARI involving such reclamation.

• On November 20, 1973, the government, through the Commissioner of Public Highways, signed a
contract with the Construction and Development Corporation of the Philippines (CDCP) to reclaim
certain foreshore and offshore areas of Manila Bay. The contract also included the construction
of Phases I and II of the Manila Cavite Coastal Road. CDCP obligated itself to carry out all the
works in consideration of fifty percent of the total reclaimed land.

• President Ferdinand E. Marcos issued Presidential Decree No. 1084 creating PEA. PD No. 1084
tasked PEA "to reclaim land, including foreshore and submerged areas," and "to develop,
improve, acquire, . . . lease and sell any and all kinds of lands." then President Marcos issued
Presidential Decree No. 1085 transferring to PEA the "lands reclaimed in the foreshore and
offshore of the Manila Bay " under the Manila-Cavite Coastal Road and Reclamation Project
(MCCRRP).

• On January 19, 1988, then President Corazon C. Aquino issued Special Patent No. 3517, granting
and transferring to PEA "the parcels of land so reclaimed under the Manila-Cavite Coastal Road
and Reclamation Project (MCCRRP) containing a total area of 1,915,894 square meters.
Subsequently, the Register of Deeds of the Municipality of Parañaque issued Transfer Certificates
 of Title Nos. 7309, 7311, and 7312, in the name of PEA, covering the three reclaimed islands
known as the "Freedom Islands" located at the southern portion of the Manila-Cavite Coastal
Road, Parañaque City. The Freedom Islands have a total land area of 1,578,441 square meters or
157.841 hectares.

• PEA entered into a Joint Venture Agreement with AMARI, a private corporation, to develop the
Freedom Islands. The JVA also required the reclamation of an additional 250 hectares of
submerged areas surrounding these islands to complete the configuration in the Master
Development Plan of the Southern Reclamation Project-MCCRRP. PEA and AMARI entered into
the JVA through negotiation without public bidding. The Board of Directors of PEA issue a
resolution confirming the JVA, the on June 1995 President Ramos approved the JVA.

• On November 29, 1996, then Senate President Ernesto Maceda delivered a privilege speech in
the Senate and denounced the JVA as the "grandmother of all scams." The Senate Committee
concluded in their report that: (1) the reclaimed lands PEA seeks to transfer to AMARI under the
JVA are lands of the public domain which the government has not classified as alienable lands
and therefore PEA cannot alienate these lands; (2) the certificates of title covering the Freedom
Islands are thus void, and (3) the JVA itself is illegal. President Ramos created a Legal Task Force
to conduct a study on the legality of the JVA in view of Senate Committee Report No. 560. The
Legal Task Force upheld the legality of the JVA, contrary to the conclusions reached by the
Senate Committees.

• On April 27, 1998, petitioner Frank I. Chavez as a taxpayer, filed the instant Petition for
Mandamus with Prayer for the Issuance of a Writ of Preliminary Injunction and Temporary
Restraining Order. Petitioner contends the government stands to lose billions of pesos in the sale
by PEA of the reclaimed lands to AMARI. Petitioner prays that PEA publicly disclose the terms of
any renegotiation of the JVA, invoking Section 28, Article II, and Section 7, Article III, of the 1987
Constitution on the right of the people to information on matters of public concern. Petitioner
assails the sale to AMARI of lands of the public domain as a blatant violation of Section 3, Article
XII of the 1987 Constitution prohibiting the sale of alienable lands of the public domain to private
corporations. Finally, petitioner asserts that he seeks to enjoin the loss of billions of pesos in
properties of the State that are of public dominion.

• After several motions for extension of time, PEA and AMARI filed their Comment Meanwhile, on
December 28, 1998, petitioner filed an Omnibus Motion: (a) to require PEA to submit the terms
of the renegotiated PEA-AMARI contract; (b) for issuance of a temporary restraining order; and
(c) to set the case for hearing on oral argument.

• On March 30, 1999, PEA and AMARI signed the Amended Joint Venture Agreement (Amended
JVA,). On May 28, 1999, President Estrada approved the Amended JVA. Due to the approval of
the Amended JVA by President Estrada, petitioner now prays that on "constitutional and statutory
grounds the renegotiated contract be declared null and void."

ISSUE:

Whether stipulations in the Amended JVA for the transfer to AMARI of lands, reclaimed or to be
reclaimed, violate the Constitution.

HELD: YES

• Under the Public Land Act (CA 141, as amended), reclaimed lands are classified as alienable and
disposable lands of the public domain Section 3 of the Constitution: Alienable lands of the public
 domain shall be limited to agricultural lands. Private corporations or associations may not hold
such alienable lands of the public domain except by lease. The 157.84 hectares of reclaimed
lands comprising the Freedom Islands, now covered by certificates of title in the name of
PEA, are alienable lands of the public domain. PEA may lease these lands to private
corporations but may not sell or transfer ownership of these lands to private corporations.
PEA may only sell these lands to Philippine citizens, subject to the ownership limitations in the
1987 Constitution and existing laws. Clearly, the Amended JVA violates glaringly Sections 2 and
3, Article XII of the 1987 Constitution. The Court must perform its duty to defend and uphold the
Constitution, and therefore declares the Amended JVA null and void ab initio.

• The reclaimed Freedom Islands: The assignment to PEA of the ownership and administration
of the reclaimed areas in Manila Bay, coupled with President Aquino’s actual issuance of a
special patent covering the Freedom Islands, is equivalent to an official proclamation
classifying the Freedom Islands as alienable or disposable lands of the public domain. They
also constitute a declaration that the Freedom Islands are no longer needed for public service.
The Freedom Islands are thus alienable or disposable lands of the public domain, open to
disposition or concession to qualified parties.

• The submerged areas: The mere reclamation of foreshore and submerged areas by PEA does
not convert these inalienable natural resources of the State into alienable or disposable lands
of the public domain. There must be a law or presidential proclamation officially classifying
these reclaimed lands as alienable or disposable and open to disposition or concession. Moreover,
these reclaimed lands cannot be classified as alienable or disposable if the law has reserved them
for some public or quasi-public use.

• PEA’s authority to sell: In order for PEA to sell its reclaimed foreshore and submerged alienable
lands of the public domain, there must be legislative authority empowering PEA to sell these
lands, in view of the requirement under CA No. 141. Without such legislative authority, PEA
could not sell but only lease its reclaimed foreshore and submerged alienable lands of the
public domain. PEA’s Charter grants it such express legislative authority to sell its lands, whether
patrimonial or alienable lands of the public domain. Nevertheless, any legislative authority
granted to PEA to sell its reclaimed alienable lands of the public domain would be subject to the
constitutional ban on private corporations from acquiring alienable lands of the public domain.
Hence, such legislative authority could only benefit private individuals.

• Registration of alienable lands of the public domain: Registration of land under Act No. 496 or
PD No. 1529 does not vest in the registrant private or public ownership of the land.
Registration is not a mode of acquiring ownership but is merely evidence of ownership
previously conferred by any of the recognized modes of acquiring ownership. Registration
does not give the registrant a better right than what the registrant had prior to the registration.
The registration of lands of the public domain under the Torrens system, by itself, cannot convert
public lands into private lands. Jurisprudence holding that upon the grant of the patent or
issuance of the certificate of title the alienable land of the public domain automatically becomes
private land cannot apply to government units and entities like PEA.