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DIRECTOR OF LANDS v. IAC

This case has been cited 6 times or more.

	GR No. 157988 2013-12-11	REPUBLIC–BUREAU OF FOREST DEVELOPMENT v. VICENTE ROXAS LEONARDO-DE CASTRO, J.
The burden of proof in overcoming the presumption of State ownership of lands of the public domain is on the person applying for registration, or in this case, for homestead patent. The applicant must show that the land subject of the application is alienable or disposable.[53] It must be stressed that incontrovertible evidence must be presented to establish that the land subject of the application is alienable or disposable.[54]
	GR No. 175064 2009-09-18	PROVINCE OF CAMARINES SUR v. CA CHICO-NAZARIO, J.
Camarines Sur cannot claim that Plaza Rizal is part of its patrimonial property. The basis for the claim of ownership of Camarines Sur, i.e., the tax declaration[39] covering Plaza Rizal in the name of the province, hardly convinces this Court. Well-settled is the rule that a tax declaration is not conclusive evidence of ownership or of the right to possess land, when not supported by any other evidence. The same is merely an indicia of a claim of ownership.[40] In the same manner, the Certification[41] dated 14 June 1996 issued by the Department of Environment and Natural Resources-Community Environment and Natural Resources Office (DENR-CENRO) in favor of Camarines Sur, merely stating that the parcel of land described therein, purportedly Plaza Rizal, was being claimed solely by Camarines Sur, hardly constitutes categorical proof of the alleged ownership of the said property by the province.
	GR No. 173808 2008-09-17	FERNANDA ARBIAS v. REPUBLIC CHICO-NAZARIO, J.
Petitioner's presentation of tax declarations of the subject property for the years 1983, 1989, 1991 and 1994, as well as tax receipts of payment of the realty tax due thereon, are of little evidentiary weight. Well-settled is the rule that tax declarations and receipts are not conclusive evidence of ownership or of the right to possess land when not supported by any other evidence. The fact that the disputed property may have been declared for taxation purposes in the names of the applicants for registration or of their predecessors-in-interest does not necessarily prove ownership. They are merely indicia of a claim of ownership.[29]
	GR NO. 160065 2006-02-28	FELINO EBREO v. GIL EBREO CHICO-NAZARIO, J.
Petitioners next argue that Tax Declaration No. 48221 in the name of Santiago Puyo enjoys the presumption of regularity in its issuance. It is a good time as any to re-state that this rule is a mere presumption, not absolute nor inflexible and applies only in the absence of proof to the contrary.[21] Besides, the mere fact that the disputed property may have been declared for taxation purposes in the name of the petitioners does not necessarily prove ownership. In the same manner, neither does the payment of taxes conclusively prove ownership of the land paid for.[22] It is merely an indicium of a claim of ownership.[23]