2Republic v. Bantigue Point Development Corp.

Bantigue Point Development Corporation filed with RTC an application for original
registration of title over a parcel of land located in Rosarion, Batangas. Petitioner
Republic filed its Opposition to the application for registration.

Among the documents presented by respondent in support of its application are

Tax Declarations, a Deed of Absolute Sale in its favor, and a Certification from
DENR Community Environment and Natural Resources Office (CENRO) of Batangas
City that the lot in question is within the alienable and disposable zone. Thereafter,
it awarded the land to respondent Corporation. Dissatisfied with the CA’s ruling,
petitioner Republic went to SC.

Issue: WON a certification from the CENRO is sufficient proof that the
property in question is alienable and disposable land of the public domain.

Ruling:
No. A certification from the CENRO is not sufficient proof that the property
in question is alienable and disposable land of the public domain.
The applicant must also show sufficient proof that the DENR Secretary has
approved the land classification and released the land in question as alienable and
disposable.

Thus, the present rule is that an application for original registration must be
accompanied by (1) a CENRO or PENRO Certification; and (2) a copy of the original
classification approved by the DENR Secretary and certified as a true copy by the
legal custodian of the official records.

Here, respondent Corporation only presented a CENRO certification in support of

its application. Clearly, this falls short of the requirements for original registration.

WHEREFORE, the instant Petition for Review is DENIED and REMANDED to the
Municipal Trial Court of San Juan, Batangas, for reception of evidence to prove that
the property sought to be registered is alienable and disposable land of the public
domain.