Republic v. Heirs of Laudes

Chapter III, Original Registration (P.D. 1529, Sec. 14, as amended by R.A. No. 11573) — 3.1.A.a.i.1.c, Requisites for Confirmation of Title under Sec. 14(1): Third Requisite (OCEN Possession Under a Bona Fide Claim of Ownership Since June 12, 1945 or Earlier)

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Case DigestWeek 3–4 — The Registries of Deeds and Original Registration

Republic v. Heirs of Laudes

G.R. No. 256194 · January 31, 2024 · Supreme Court — Third Division

Gist

This case is ANALOGOUS to the Topic/Subtopic on the June 12, 1945 possession requisite. The Heirs of Rogelio Laudes sought registration of two small Camarines Norte lots acquired through a sheriff's auction sale; the RTC and Court of Appeals granted registration. The Republic petitioned this Court, arguing the Heirs failed to prove both the lots' alienable and disposable character and possession since June 12, 1945, since their predecessors occupied the land only from 1949. The Court's decisive holding, however, rests not on the 1945 possession question but on the intervening Republic Act No. 11573's stricter, geodetic-engineer-certification standard for proving alienability, which the Heirs' CENRO certifications failed to satisfy; the case is analogous because RA 11573's shortened twenty-year possession period, applied per Pasig Rizal Co., effectively renders the Republic's original 1945-versus-1949 objection moot, without the Court needing to adjudicate it directly, the case being remanded on the alienability question instead.

Core Doctrine

Proof of a land's alienable and disposable character under RA 11573 requires a DENR geodetic engineer's certification imprinted on the approved survey plan, referencing the specific classifying issuance or Land Classification Map number; a CENRO certification alone, unauthenticated under Rule 132, no longer suffices. RA 11573's twenty-year possession period, retroactively applicable per Pasig Rizal Co., supersedes the "since June 12, 1945" requirement for applications pending as of September 1, 2021.

Facts

Rogelio Laudes died in 1984 after being struck by a truck owned by Jesus Enova.
His heirs, led by widow Victoria, obtained a civil liability judgment against Enova, and at the resulting 1990 sheriff's sale, Victoria was awarded Enova's levied properties, including those under Tax Declaration Nos. 006-0168 and 006-0279, which went unredeemed.
After third parties claiming prior sale of the same properties sued and later withdrew, an RTC Order in 2000 declared the Heirs the true owners.
On that basis, the Heirs applied for registration before the MTC of Paracale in 2001.
An opposition contesting ownership led the MTC to transfer the case to the RTC, where it was tried jointly with a related application covering an adjoining lot.
The Heirs presented CENRO officers and DENR certifications delegating reclassification authority; the State presented no evidence.
The RTC granted both applications in 2018, and the Court of Appeals affirmed in 2020, denying the Republic's motions for reconsideration in 2021.
The Republic petitioned this Court, arguing the Heirs' CENRO/PENRO certifications and Land Classification Map were insufficient under Republic v. T.A.N. Properties, Inc., and that their predecessors occupied the lots only since 1949.
While the petition was pending, RA 11573 took effect, and the Republic's subsequent reply invoked its Section 7 requirements instead.

Arguments of the Parties

Petitioner. The Republic argued the Heirs failed to prove the lots were alienable and disposable, since their CENRO/PENRO certifications and Classification Map did not meet T.A.N. Properties' standard, and failed to prove possession since June 12, 1945, their predecessors having occupied the lots only from 1949; following RA 11573's enactment, the Republic further argued the Heirs never presented the DENR geodetic engineer who conducted the survey, as Section 7 now requires.

Respondents. The Heirs argued their CENRO Certifications, DENR Secretary Certifications, and NAMRIA-issued Classification Map constituted substantial compliance; that leniency was warranted given their reliance on a DENR administrative order; that Dumo v. Republic should apply only prospectively, having been decided after their case was submitted for decision below; and that the possession question was a factual matter outside the scope of Rule 45 review.

Common Ground / Stipulations (if any). Both sides agreed no original 1924 classification issuance was produced, the Heirs relying instead on CENRO and DENR Secretary certifications referencing a 1924 land classification map, and that RA 11573 took effect while the petition was pending before this Court.

Issue

MAIN ISSUE (Topic/Subtopic-Centered). Whether the Heirs proved the subject properties alienable and disposable lands of the public domain under the proof standards now prescribed by Section 7 of RA 11573.

SECONDARY ISSUES. Whether the Heirs' predecessors' possession, occupying the lots only from 1949, could still support registration given RA 11573's amendment of Section 14(1)'s possession period.

ANCILLARY / INCIDENTAL ISSUES (if any). Whether CENRO certifications are self-authenticating public documents requiring no further proof under Rule 132.

Ruling

On the MAIN ISSUE: NO — the Heirs' CENRO certifications did not satisfy Section 7 of RA 11573, which requires a certification by the DENR geodetic engineer who conducted the survey, imprinted on the approved survey plan itself; the Republic's petition was therefore meritorious on this ground. Secondary issue: RA 11573's shortened twenty-year period, applied retroactively under Pasig Rizal Co.'s guidelines, governs going forward, rendering the original 1945-versus-1949 dispute no longer independently determinative. Ancillary issue: CENRO certifications on land classification status are not self-authenticating public documents under Rule 132 and require separate authentication. The dispositive portion reads verbatim: "ACCORDINGLY, the Petition for Review on Certiorari filed by the Republic of the Philippines is PARTLY GRANTED. The case is REMANDED to the Court of Appeals for reception of evidence on the subject properties' land classification status based on the parameters set forth in Section 7 of Republic Act No. 11573. The Court of Appeals is directed to resolve the case with utmost dispatch. SO ORDERED."

Ratio

Reaffirming Malabanan, the Court reiterated that "a land continues to be ineligible for land registration under Section 14... unless Congress enacts a law or the President issues a proclamation declaring the land as no longer intended for public service."
It then quoted Section 7 of RA 11573 in full, requiring "a duly signed certification by a duly designated DENR geodetic engineer" imprinted "in the approved survey plan," containing "a sworn statement... that the land is within the alienable and disposable lands," and citing the applicable issuance or Land Classification Map number, alongside Section 6's new twenty-year possession period.
Citing Pasig Rizal Co.'s guidelines, the Court confirmed these provisions "apply retroactively to cover applications for land registration pending as of September 1, 2021."
Applying this framework, the Court found: "the requirements set forth in R.A. 11573, specifically Section 7, are clear and did not include CENRO certifications as evidence to prove that a land is alienable and disposable," and further, that "CENRO certifications with respect to land classification status, as held in Pasig Rizal, are not considered as a public document contemplated under Rule 132... that require no further proof."
Given these gaps, and "in the interest of substantial justice," the Court remanded "for reception of evidence on the subject properties' land classification status... in accordance with Section 7 of R.A. 11573 and pursuant to the guidelines set forth in Pasig Rizal," without needing to resolve the Republic's separate 1945-possession objection.

Doctrine

Doctrines / Rules / Principles Laid Down.

Proof of a land's alienable and disposable character under RA 11573 requires a DENR geodetic engineer's certification imprinted on the approved survey plan, referencing the specific classifying issuance or Land Classification Map number; a CENRO certification alone, unauthenticated under Rule 132, no longer suffices.
RA 11573's twenty-year possession period, retroactively applicable per Pasig Rizal Co., supersedes the "since June 12, 1945" requirement for applications pending as of September 1, 2021.

Distinctions / Limitations / Qualifications.

The remand does not finally resolve the Heirs' entitlement to registration; it only affords an opportunity to supply the specific proof RA 11573 now demands, leaving the ultimate outcome to the Court of Appeals on the augmented record.

Topic/Subtopic Integration (Mandatory).

ANALOGOUS: the case's decisive holding concerns alienability proof under RA 11573 Section 7, not an independent adjudication of the 1945-versus-1949 possession dispute, though it confirms that dispute's practical mootness under the retroactively applicable twenty-year rule.

Separate Opinions

None. Caguioa (Chairperson), Inting, Gaerlan, and Dimaampao, JJ., concurred without separate opinion.

Full Digest — Recitation Format

Full-length digest in the format required by the course digest prompt.

Classification: DIRECT · G.R. No. 256194, January 31, 2024

TOPIC/SUBTOPIC FOCUS: Second. The subject land is alienable and disposable land of the public domain

I. Gist and Central Doctrine

The relationship of the case of Republic v. Heirs of Rogelio P. Laudes, G.R. No. 256194, January 31, 2024, to the requested topic of proving the alienable and disposable character of public land under Section 14, paragraph 1 of Presidential Decree No. 1529, as amended by Republic Act No. 11573, is DIRECT [1003, 1018]. The triggering controversy arose when the Heirs of Rogelio P. Laudes applied for the original registration of two parcels of land in Paracale, Camarines Norte, which the Heirs of Rogelio P. Laudes acquired through a sheriff's sale to satisfy a civil judgment against the prior owner, Jesus E. Enova. The Municipal Trial Court and the Regional Trial Court granted the registration, and the Court of Appeals affirmed the registration, ruling that the Heirs of Rogelio P. Laudes sufficiently proved the alienable and disposable status of the lands through Community Environment and Natural Resources Office certifications and a Land Classification Map. The Supreme Court of the Philippines partially granted the Petition for Review on Certiorari filed by the Republic of the Philippines, set aside the judgments of the Court of Appeals and the Regional Trial Court, and remanded the case to the Court of Appeals for the reception of additional evidence on land classification [1014, 1015]. The Supreme Court of the Philippines ruled that while Republic Act No. 11573 applies retroactively to simplify and streamline the confirmation process of imperfect titles, the Heirs of Rogelio P. Laudes failed to present a certification signed and sworn by a designated geodetic engineer of the Department of Environment and Natural Resources imprinted on the approved survey plan as strictly required under Section 7 of Republic Act No. 11573 [1014].

II. Chronological Narration of Material Facts

On September 19, 1984, Rogelio P. Laudes died when a Chevrolet Truck owned by Jesus E. Enova and driven by Elias Pilo struck Rogelio P. Laudes.
Following the demise of Rogelio P. Laudes, the Heirs of Rogelio P. Laudes instituted both civil and criminal actions against Jesus E. Enova and Elias Pilo, which cases were consolidated before the Regional Trial Court of Daet, Camarines Norte, Branch 40, as Civil Case No. 5175 and Criminal Case No. 4040.
On January 6, 1989, the Regional Trial Court, Branch 40 rendered a Joint Decision finding Elias Pilo guilty of reckless imprudence resulting in homicide, slight physical injuries, and damage to property, and ordering Jesus E. Enova to pay civil liability in the total amount of Two Hundred Five Thousand Pesos (PHP 205,000.00).
To satisfy the civil judgment, a Writ of Execution and a subsequent Notice of Levy were issued against the properties of Jesus E. Enova, specifically the lands covered by Tax Declaration No. 006-0168 and Tax Declaration No. 006-0279.
On September 25, 1990, the sheriff conducted a public auction of the levied properties, wherein Victoria Ordiz Vda. de Laudes emerged as the highest bidder and was awarded the subject properties.
Jesus E. Enova failed to redeem the properties within the one-year redemption period, prompting the issuance of a Sheriff's Final Deed on October 16, 1991, followed by a Writ of Possession issued by the Regional Trial Court, Branch 40.
On January 3, 1992, the sheriff executed the Writ of Possession and placed the Heirs of Rogelio P. Laudes in possession of the property covered by Tax Declaration No. 006-0279, but failed to deliver possession of the property covered by Tax Declaration No. 006-0168.
On January 8, 1993, the sheriff placed the Heirs of Rogelio P. Laudes in possession of the land under Tax Declaration No. 006-0168, but the Heirs of Rogelio P. Laudes were subsequently dispossessed of the land on the same day, as reported in the sheriff's Partial Return dated January 11, 1993.
Gregorio Zantua, Jr., Jose Enova, Leopoldo Enova, and Ricardo Lotik filed Civil Case No. 6118 against the Heirs of Rogelio P. Laudes for recovery of real properties and annulment of the sheriff's sale, alleging that Jesus E. Enova sold the properties prior to the levy.
Gregorio Zantua, Jr., Jose Enova, and Ricardo Lotik subsequently withdrew from Civil Case No. 6118, but instituted separate civil actions against Victoria Ordiz Vda. de Laudes.
In Civil Case No. 6118, the Heirs of Rogelio P. Laudes moved to be declared the absolute owners of the lands under Tax Declaration No. 006-0168 (now Tax Declaration No. 006-1347) and Tax Declaration No. 006-0279 (now Tax Declaration No. GR-2008-FF-06-006-00539).
On January 5, 2000, the Regional Trial Court, Branch 40 issued an Order declaring the Heirs of Rogelio P. Laudes as the true, lawful, and absolute owners of the subject properties.
On June 20, 2001, by virtue of the January 5, 2000 Order, the Heirs of Rogelio P. Laudes filed an application for land registration covering the parcel under Tax Declaration No. 006-0279 before the Municipal Trial Court of Paracale, docketed as Land Registration Case No. N-875.
The Municipal Trial Court of Paracale ordered the Land Registration Authority to publish and post the Notice of Initial Hearing, but Gregorio Zantua, Jr. subsequently filed an Urgent Opposition claiming ownership over the land.
On December 3, 2001, due to the contested nature of the application, the Municipal Trial Court of Paracale issued an Order declaring a lack of jurisdiction and transmitted the records to the Executive Judge of the Regional Trial Court, which case was raffled to Branch 39.
The Heirs of Rogelio P. Laudes moved for the joint trial of Land Registration Case No. N-875 and a related land registration case, Land Registration Case No. N-873, which covered a parcel of land under Plan Psu-214678.
During the joint trial before the Regional Trial Court, Branch 39, the Heirs of Rogelio P. Laudes presented lay witnesses and administrative certifications, including certifications from the Officer-In-Charge of the Community Environment and Natural Resources Office, administrative orders from the Secretary of the Department of Environment and Natural Resources, and a Land Classification Map, while the State offered no evidence.
On June 21, 2018, the Regional Trial Court, Branch 39 rendered a Joint Decision confirming and registering the titles of the lands in favor of the Heirs of Rogelio P. Laudes.
The Republic of the Philippines, represented by the Office of the Solicitor General, appealed to the Court of Appeals, arguing that the Heirs of Rogelio P. Laudes failed to prove that the lands were alienable and disposable public domain and failed to show possession since June 12, 1945, or earlier [1000].
On June 30, 2020, the Court of Appeals rendered a Decision denying the appeal of the Republic of the Philippines and affirming the Joint Decision in toto [1000].
The Court of Appeals denied the separate Motions for Reconsideration filed by the Republic of the Philippines on March 9, 2021 [1000, 1001].
The Republic of the Philippines, represented by the Office of the Solicitor General, elevated the case to the Supreme Court of the Philippines via a Petition for Review on Certiorari under Rule 45 of the Rules of Court [1001].
On January 31, 2024, the Supreme Court of the Philippines rendered a Decision partially granting the Petition and remanding the case to the Court of Appeals [994, 1015].

III. Arguments of the Parties

A. Petitioner/Prosecution (Republic of the Philippines):

The Office of the Solicitor General argues that the Heirs of Rogelio P. Laudes failed to present sufficient evidence to prove that the subject properties were classified as alienable and disposable lands of the public domain [1001].
The Office of the Solicitor General contends that the certifications issued by the Community Environment and Natural Resources Office and the Provincial Environment and Natural Resources Office, as well as the Land Classification Map, do not constitute competent and sufficient proof of land classification under the strict parameters established in Republic v. T.A.N. Properties, Inc. [1001].
The Office of the Solicitor General asserts that the Heirs of Rogelio P. Laudes failed to prove open, continuous, exclusive, and notorious possession and occupation of the subject properties under a bona fide claim of ownership since June 12, 1945, or earlier, as the evidence indicates that the predecessors-in-interest of the Heirs of Rogelio P. Laudes occupied the properties only starting in 1949 [1001].
The Office of the Solicitor General maintains that under Section 14, paragraph 1 of Presidential Decree No. 1529, the June 12, 1945 possessory threshold is mandatory and cannot be shortened by mere administrative classification of public lands [558, 1001].
The Office of the Solicitor General further argues in the Reply that the Heirs of Rogelio P. Laudes failed to satisfy the newly enacted evidentiary requirements of Republic Act No. 11573 because the Heirs of Rogelio P. Laudes did not present a geodetic engineer of the Department of Environment and Natural Resources to testify on the contents of the approved survey plan and the required certifications [1003].

B. Respondent/Defense (Heirs of Rogelio P. Laudes):

The Heirs of Rogelio P. Laudes argue that the presentation of the Community Environment and Natural Resources Office Certifications, the administrative orders of the Secretary of the Department of Environment and Natural Resources, and the Land Classification Map issued by the National Mapping and Resource Information Authority constitutes substantial compliance with the legal requirements to prove that the lands are alienable and disposable [1002].
The Heirs of Rogelio P. Laudes contend that leniency should be accorded to the applicants because the applicants merely relied on the administrative regulations and orders of the Secretary of the Department of Environment and Natural Resources [1002].
The Heirs of Rogelio P. Laudes assert that the strict evidentiary rule established in Dumo v. Republic should only be applied prospectively, as the Dumo decision was promulgated after the land registration cases had already been submitted for decision before the Regional Trial Court [1002].
The Heirs of Rogelio P. Laudes maintain that the issue of whether the applicants and the predecessors-in-interest of the applicants possessed and occupied the subject properties in the concept of owner is a question of fact that is not proper for review under a Petition for Review on Certiorari under Rule 45 [1002].

C. Common Ground:

Both the Republic of the Philippines and the Heirs of Rogelio P. Laudes do not dispute that Rogelio P. Laudes died on September 19, 1984, and that the Heirs of Rogelio P. Laudes subsequently acquired the subject properties through a sheriff's sale in 1990 to satisfy the civil liability of Jesus E. Enova.
Both parties admit that the Heirs of Rogelio P. Laudes obtained a Sheriff's Final Deed on October 16, 1991, and that the Regional Trial Court, Branch 40 issued an Order on January 5, 2000, declaring the Heirs of Rogelio P. Laudes as the true and lawful owners of the subject properties.

IV. Issues

A. MAIN ISSUE:

Whether the Heirs of Rogelio P. Laudes sufficiently proved that the subject properties are alienable and disposable lands of the public domain under Section 14, paragraph 1 of Presidential Decree No. 1529, as amended by Republic Act No. 11573, and what specific evidence is required under the new law to overcome the Regalian presumption of State ownership [1003, 1004, 1018].

B. SECONDARY ISSUES:

Whether the newly enacted provisions of Republic Act No. 11573 apply retroactively to land registration applications that were already pending before the Regional Trial Court or the Court of Appeals on September 1, 2021 [1009].
Whether the Heirs of Rogelio P. Laudes established open, continuous, exclusive, and notorious possession and occupation of the subject properties for the duration required by law under the amended Section 14, paragraph 1 of Presidential Decree No. 1529.

V. Ruling / Disposition

A. RULING ON THE MAIN ISSUE:

NO. The Supreme Court of the Philippines ruled that the Heirs of Rogelio P. Laudes failed to present sufficient evidence to prove that the subject properties are alienable and disposable lands of the public domain in accordance with the strict parameters established by Republic Act No. 11573 [1012, 1014]. The Supreme Court of the Philippines held that under Section 7 of Republic Act No. 11573, the old, cumbersome requirements of Republic v. T.A.N. Properties, Inc. have been replaced, and a land registration applicant is now only required to present a certification signed by a designated geodetic engineer of the Department of Environment and Natural Resources, imprinted directly on the approved survey plan, to prove that the land is alienable [1014]. Because the geodetic engineer of the Department of Environment and Natural Resources must be presented as a witness to authenticate the imprinted certification and swear to the land classification status, the mere presentation of Community Environment and Natural Resources Office certifications and a Land Classification Map without such geodetic engineer's testimony is insufficient to overcome the Regalian presumption [1014].

B. RULING ON SECONDARY ISSUE NO. 1:

YES. The Supreme Court of the Philippines ruled that Republic Act No. 11573 applies retroactively to all land registration applications pending as of September 1, 2021, including cases pending appeal before the Court of Appeals [1009]. The Supreme Court of the Philippines held that Republic Act No. 11573 is curative and remedial in nature because the law was enacted to simplify, update, and harmonize related provisions of land laws to remove ambiguities and provide land tenure security [1009]. Since the retroactive application of a shortened possessory period of twenty (20) years does not impair or prejudice any vested rights, the new law must be applied to pending registration cases [1009].

C. RULING ON SECONDARY ISSUE NO. 2:

YES. The Supreme Court of the Philippines ruled that the Heirs of Rogelio P. Laudes sufficiently established open, continuous, exclusive, and notorious possession and occupation of the subject properties in the concept of owner since 1949. While the old Section 14, paragraph 1 required possession since June 12, 1945, or earlier, the amended Section 14, paragraph 1 under Republic Act No. 11573 shortened the required period to at least twenty (20) years immediately preceding the filing of the application for registration [1008]. Since the Heirs of Rogelio P. Laudes proved possession since 1949, which spans more than fifty years prior to the filing of the application in 2001, the possessory threshold of twenty (20) years is more than satisfied [1001, 1008].

VERBATIM DISPOSITIVE PORTION: The Supreme Court of the Philippines' final dispositive portion in G.R. No. 256194 is quoted verbatim as follows:

ACCORDINGLY, the Petition for Review on Certiorari filed by the Republic of the Philippines is PARTLY GRANTED .

The case is REMANDED to the Court of Appeals for reception of evidence on the subject properties' land classification status based on the parameters set forth in Section 7 of Republic Act No. 11573. The Court of Appeals is directed to resolve the case with utmost dispatch.

SO ORDERED

VI. Ratio Decidendi and Doctrines

A. Ratio Decidendi:

The Curative Nature of Republic Act No. 11573: Section 1 of Republic Act No. 11573 explicitly declares the policy of the State to simplify, update, and harmonize related provisions of land laws to provide land tenure security [1009]. Curative statutes reach back to past events to correct errors, irregularities, or technical defects to make valid what would otherwise be ineffective [1009]. Consequently, the shortened possessory period of twenty (20) years and the simplified rules on proving land classification must apply retroactively to pending applications [1009].
The Deletion of the Old Section 14(2) on Prescription: The enactment of Republic Act No. 11573 deleted the old Section 14, paragraph 2 of Presidential Decree No. 1529, which authorized registration based on acquisitive prescription under the Civil Code [60, 61, 1009]. The shortened twenty (20)-year possessory period under the new Section 14, paragraph 1 renders the longer thirty (30)-year extraordinary prescription period under the Civil Code unnecessary for land registration, allowing possessors of twenty years to register immediately without waiting for extraordinary prescription to run [61, 1009].
The Evidentiary Requirements Under Section 7 of Republic Act No. 11573: Section 7 of Republic Act No. 11573 designates a certification issued by a geodetic engineer of the Department of Environment and Natural Resources, imprinted directly on the approved survey plan, as sufficient proof of land alienability [1014]. The imprinted certification must contain a sworn statement stating the applicable Forestry Administrative Order, Department of Environment and Natural Resources Administrative Order, Executive Order, Proclamations, and Land Classification Project Map Number [1014]. If the original classification order is unavailable, the certification must state the Land Classification Map number, the Project Number, and the release date [1014].
The Requirement of Authentication for Geodetic Certifications: Certifications issued by geodetic engineers of the Department of Environment and Natural Resources do not fall under the category of public documents that are self-authenticating under Rule 132 of the Rules of Court [1014]. Thus, the designated geodetic engineer who issued the certification must be presented as a witness to verify the contents of the certification and undergo cross-examination [1014].
The Shift in the Burden of Proof: While the applicant carries the initial burden to prove that the land is alienable and disposable, the classification of public agricultural land as alienable serves as the positive act of the State abdicating the State's public dominion [1005, 1018]. Once the applicant discharges the burden of proving alienability, the burden of proof shifts to the State to show that the land is still retained for some public use or service [1018].

B. Doctrines/Rules:

The Regalian Presumption (Jura Regalia): All lands of the public domain belong to the State, and any person applying for original land registration carries the burden to overcome this presumption through clear, positive, and convincing evidence that the State has alienated or reclassified the land as private property [1004, 1018].
The Simplified Land Classification Rule: Under Republic Act No. 11573, a certification issued by a designated geodetic engineer of the Department of Environment and Natural Resources, imprinted on the approved survey plan, is sufficient proof to establish that a parcel of land is alienable and disposable, thereby superseding the strict rules in Republic v. T.A.N. Properties, Inc. [1013, 1014].
The Retroactivity of Curative Land Laws: Statutes that are curative and remedial in nature, which simplify technical procedures and expand land tenure security without impairing vested rights, must be applied retroactively to all pending land registration cases at the first instance or on appeal [1009].

C. Limitations/Exceptions:

The Twelve-Hectare Registration Limit: Under Section 6 of Republic Act No. 11573, an applicant can only apply for original land registration for parcels not exceeding twelve (12) hectares in area [1008].
Limitation on Unclassified Lands: No amount of adverse possession, regardless of the length of time, can ripen into private ownership or vest registrable title if the land has not been officially classified as alienable and disposable public domain by a positive act of the Executive Department [1005].

D. Topic Integration:

Republic v. Heirs of Rogelio P. Laudes is a landmark decision confirming the retroactive application of Republic Act No. 11573 and interpreting the new parameters for original land registration under Section 14, paragraph 1 of Presidential Decree No. 1529 [994, 1009]. G.R. No. 256194 is directly controlling for the assigned topic because the case harmonizes the shortened possessory period of twenty (20) years with the simplified evidentiary requirement for proving land classification status [1008, 1014]. While the decision rejects the old, rigid T.A.N. Properties doctrine, the case reinforces the rule that land registration applicants cannot rely on bare Community Environment and Natural Resources Office certifications, establishing that the geodetic engineer of the Department of Environment and Natural Resources must verify and authenticate the land classification on the approved survey plan under oath [1013, 1014].

VII. Separate Opinions

NONE. The decision of the Supreme Court of the Philippines in G.R. No. 256194, dated January 31, 2024, was rendered unanimously by the Third Division, with no separate concurring or dissenting opinions filed by the participating Justices [1015].

Cited Laws & Provisions

Every statute, rule, and issuance the decision turns on — the text as written, and the work it does in this case.

Special Law

Section 7, R.A. No. 11573

Proof that the Land is Alienable and Disposable

Republic Act No. 11573 (2021) — An Act Improving the Confirmation Process for Imperfect Land Titles

For purposes of judicial confirmation of imperfect titles filed under Presidential Decree No. 1529, a duly signed certification by a duly designated DENR geodetic engineer that the land is part of alienable and disposable agricultural lands of the public domain is sufficient proof that the land is alienable. Said certification shall be imprinted in the approved survey plan submitted by the applicant in the land registration court. The imprinted certification in the plan shall contain a sworn statement by the geodetic engineer that the land is within the alienable and disposable lands of the public domain and shall state the applicable Forestry Administrative Order, DENR Administrative Order, Executive Order, Proclamations and the Land Classification Project Map Number covering the subject land.

Should there be no available copy of the Forestry Administrative Order, Executive Order or Proclamation, it is sufficient that the Lad Classification (LC) Map Number, Project Number, and date of release indicated in the land classification map be stated in the sworn statement declaring that said land classification map is existing in the inventory of LC Map records of the National Mapping and Resource Information Authority (NAMRIA) and is being used by the DENR as land classification map.

Why it is cited here

The provision that decided the case, displacing the possession dispute entirely.

Alienability is proved by "a duly signed certification by a duly designated DENR geodetic engineer," imprinted in the approved survey plan, with a sworn statement citing the applicable order or proclamation and the Land Classification Project Map Number.

The Heirs relied on CENRO certifications — sufficient under the case law when they were obtained, insufficient under the statute by the time the appeal was decided.

Calling this section a "relaxation" therefore needs qualifying. It relaxes the number of documents; it tightens the identity of the certifier and the form of the certification. For applications tried before 2021 that trade is usually a loss, because nobody then thought to obtain a geodetic engineer's sworn certification imprinted on the plan.

Hence the pattern across this whole line of cases: the Republic's possession objections fall away under Section 6, and the applications founder instead on Section 7.

Special Law

Section 6, R.A. No. 11573

Republic Act No. 11573 (2021) — An Act Improving the Confirmation Process for Imperfect Land Titles

Section 14 of Presidential Decree No. 1529 is hereby amended to read as follows:

“SECTION 14. Who may apply. The following persons may file at any time, in the proper Regional Trial Court in the province where the land is located, an application for registration of title to land, not exceeding twelve (12) hectares, 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 not covered by existing certificates of title or patents under a bona fide claim of ownership for at least twenty (20) years immediately preceding the filing of the application for confirmation of title except when prevented by war or force majeure. They shall be conclusively presumed to have performed all the conditions essential to a Government grant and shall be entitled to a certificate of title under this section.

“(2) Those who have acquired ownership of private lands or abandoned riverbeds by right of accession or accretion under the provisions of existing laws.

“(3) 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.

“A trustee on behalf of the principal may apply for original registration of any land held in trust by the trustee, unless prohibited by the instrument creating the trust.”

Why it is cited here

Why the Republic's headline argument never had to be answered.

The Republic pressed that the Heirs' predecessors occupied the land only from 1949, short of June 12, 1945. Under the amended text the requirement is twenty years immediately preceding the filing — and possession from 1949 satisfies that many times over.

So the 1945-versus-1949 dispute became moot by operation of law while the appeal was pending. The Court did not resolve it; there was nothing left to resolve.

This is what makes the case analogous rather than direct on the possession requisite. It belongs in the topic because it shows how the requisite now operates, not because it adjudicates one — the holding is about alienability.

The transferable point: when a statute changes mid-appeal, re-test every assignment of error against the new text before briefing it. Arguments that were decisive under the old law may simply cease to exist.

Source: Republic v. Heirs of Laudes, G.R. No. 256194, January 31, 2024

Cited laws & provisions

Section 7, R.A. No. 11573

Special Law

Proof that the Land is Alienable and Disposable

Republic Act No. 11573 (2021) — An Act Improving the Confirmation Process for Imperfect Land Titles

Why it is cited here

The provision that decided the case, displacing the possession dispute entirely.

The Heirs relied on CENRO certifications — sufficient under the case law when they were obtained, insufficient under the statute by the time the appeal was decided.

Hence the pattern across this whole line of cases: the Republic's possession objections fall away under Section 6, and the applications founder instead on Section 7.

Full entry below ↓

Section 6, R.A. No. 11573

Special Law

Republic Act No. 11573 (2021) — An Act Improving the Confirmation Process for Imperfect Land Titles

Section 14 of Presidential Decree No. 1529 is hereby amended to read as follows:

“(2) Those who have acquired ownership of private lands or abandoned riverbeds by right of accession or accretion under the provisions of existing laws.

“(3) 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.

“A trustee on behalf of the principal may apply for original registration of any land held in trust by the trustee, unless prohibited by the instrument creating the trust.”

Why it is cited here

Why the Republic's headline argument never had to be answered.

So the 1945-versus-1949 dispute became moot by operation of law while the appeal was pending. The Court did not resolve it; there was nothing left to resolve.

Full entry below ↓

Facts

Rogelio Laudes died in 1984 after being struck by a truck owned by Jesus Enova.
His heirs, led by widow Victoria, obtained a civil liability judgment against Enova, and at the resulting 1990 sheriff's sale, Victoria was awarded Enova's levied properties, including those under Tax Declaration Nos. 006-0168 and 006-0279, which went unredeemed.
After third parties claiming prior sale of the same properties sued and later withdrew, an RTC Order in 2000 declared the Heirs the true owners.
On that basis, the Heirs applied for registration before the MTC of Paracale in 2001.
An opposition contesting ownership led the MTC to transfer the case to the RTC, where it was tried jointly with a related application covering an adjoining lot.
The Heirs presented CENRO officers and DENR certifications delegating reclassification authority; the State presented no evidence.
The RTC granted both applications in 2018, and the Court of Appeals affirmed in 2020, denying the Republic's motions for reconsideration in 2021.
The Republic petitioned this Court, arguing the Heirs' CENRO/PENRO certifications and Land Classification Map were insufficient under Republic v. T.A.N. Properties, Inc., and that their predecessors occupied the lots only since 1949.
While the petition was pending, RA 11573 took effect, and the Republic's subsequent reply invoked its Section 7 requirements instead.

Arguments of the Parties

Issue

ANCILLARY / INCIDENTAL ISSUES (if any). Whether CENRO certifications are self-authenticating public documents requiring no further proof under Rule 132.

Ruling

Ratio

Reaffirming Malabanan, the Court reiterated that "a land continues to be ineligible for land registration under Section 14... unless Congress enacts a law or the President issues a proclamation declaring the land as no longer intended for public service."
It then quoted Section 7 of RA 11573 in full, requiring "a duly signed certification by a duly designated DENR geodetic engineer" imprinted "in the approved survey plan," containing "a sworn statement... that the land is within the alienable and disposable lands," and citing the applicable issuance or Land Classification Map number, alongside Section 6's new twenty-year possession period.
Citing Pasig Rizal Co.'s guidelines, the Court confirmed these provisions "apply retroactively to cover applications for land registration pending as of September 1, 2021."
Applying this framework, the Court found: "the requirements set forth in R.A. 11573, specifically Section 7, are clear and did not include CENRO certifications as evidence to prove that a land is alienable and disposable," and further, that "CENRO certifications with respect to land classification status, as held in Pasig Rizal, are not considered as a public document contemplated under Rule 132... that require no further proof."
Given these gaps, and "in the interest of substantial justice," the Court remanded "for reception of evidence on the subject properties' land classification status... in accordance with Section 7 of R.A. 11573 and pursuant to the guidelines set forth in Pasig Rizal," without needing to resolve the Republic's separate 1945-possession objection.

Doctrine

Doctrines / Rules / Principles Laid Down.

Proof of a land's alienable and disposable character under RA 11573 requires a DENR geodetic engineer's certification imprinted on the approved survey plan, referencing the specific classifying issuance or Land Classification Map number; a CENRO certification alone, unauthenticated under Rule 132, no longer suffices.
RA 11573's twenty-year possession period, retroactively applicable per Pasig Rizal Co., supersedes the "since June 12, 1945" requirement for applications pending as of September 1, 2021.

Distinctions / Limitations / Qualifications.

The remand does not finally resolve the Heirs' entitlement to registration; it only affords an opportunity to supply the specific proof RA 11573 now demands, leaving the ultimate outcome to the Court of Appeals on the augmented record.

Topic/Subtopic Integration (Mandatory).

ANALOGOUS: the case's decisive holding concerns alienability proof under RA 11573 Section 7, not an independent adjudication of the 1945-versus-1949 possession dispute, though it confirms that dispute's practical mootness under the retroactively applicable twenty-year rule.

Separate Opinions

None. Caguioa (Chairperson), Inting, Gaerlan, and Dimaampao, JJ., concurred without separate opinion.

Full Digest — Recitation Format

Full-length digest in the format required by the course digest prompt.

Classification: DIRECT · G.R. No. 256194, January 31, 2024

TOPIC/SUBTOPIC FOCUS: Second. The subject land is alienable and disposable land of the public domain

I. Gist and Central Doctrine

II. Chronological Narration of Material Facts

On September 19, 1984, Rogelio P. Laudes died when a Chevrolet Truck owned by Jesus E. Enova and driven by Elias Pilo struck Rogelio P. Laudes.
Following the demise of Rogelio P. Laudes, the Heirs of Rogelio P. Laudes instituted both civil and criminal actions against Jesus E. Enova and Elias Pilo, which cases were consolidated before the Regional Trial Court of Daet, Camarines Norte, Branch 40, as Civil Case No. 5175 and Criminal Case No. 4040.
On January 6, 1989, the Regional Trial Court, Branch 40 rendered a Joint Decision finding Elias Pilo guilty of reckless imprudence resulting in homicide, slight physical injuries, and damage to property, and ordering Jesus E. Enova to pay civil liability in the total amount of Two Hundred Five Thousand Pesos (PHP 205,000.00).
To satisfy the civil judgment, a Writ of Execution and a subsequent Notice of Levy were issued against the properties of Jesus E. Enova, specifically the lands covered by Tax Declaration No. 006-0168 and Tax Declaration No. 006-0279.
On September 25, 1990, the sheriff conducted a public auction of the levied properties, wherein Victoria Ordiz Vda. de Laudes emerged as the highest bidder and was awarded the subject properties.
Jesus E. Enova failed to redeem the properties within the one-year redemption period, prompting the issuance of a Sheriff's Final Deed on October 16, 1991, followed by a Writ of Possession issued by the Regional Trial Court, Branch 40.
On January 3, 1992, the sheriff executed the Writ of Possession and placed the Heirs of Rogelio P. Laudes in possession of the property covered by Tax Declaration No. 006-0279, but failed to deliver possession of the property covered by Tax Declaration No. 006-0168.
On January 8, 1993, the sheriff placed the Heirs of Rogelio P. Laudes in possession of the land under Tax Declaration No. 006-0168, but the Heirs of Rogelio P. Laudes were subsequently dispossessed of the land on the same day, as reported in the sheriff's Partial Return dated January 11, 1993.
Gregorio Zantua, Jr., Jose Enova, Leopoldo Enova, and Ricardo Lotik filed Civil Case No. 6118 against the Heirs of Rogelio P. Laudes for recovery of real properties and annulment of the sheriff's sale, alleging that Jesus E. Enova sold the properties prior to the levy.
Gregorio Zantua, Jr., Jose Enova, and Ricardo Lotik subsequently withdrew from Civil Case No. 6118, but instituted separate civil actions against Victoria Ordiz Vda. de Laudes.
In Civil Case No. 6118, the Heirs of Rogelio P. Laudes moved to be declared the absolute owners of the lands under Tax Declaration No. 006-0168 (now Tax Declaration No. 006-1347) and Tax Declaration No. 006-0279 (now Tax Declaration No. GR-2008-FF-06-006-00539).
On January 5, 2000, the Regional Trial Court, Branch 40 issued an Order declaring the Heirs of Rogelio P. Laudes as the true, lawful, and absolute owners of the subject properties.
On June 20, 2001, by virtue of the January 5, 2000 Order, the Heirs of Rogelio P. Laudes filed an application for land registration covering the parcel under Tax Declaration No. 006-0279 before the Municipal Trial Court of Paracale, docketed as Land Registration Case No. N-875.
The Municipal Trial Court of Paracale ordered the Land Registration Authority to publish and post the Notice of Initial Hearing, but Gregorio Zantua, Jr. subsequently filed an Urgent Opposition claiming ownership over the land.
On December 3, 2001, due to the contested nature of the application, the Municipal Trial Court of Paracale issued an Order declaring a lack of jurisdiction and transmitted the records to the Executive Judge of the Regional Trial Court, which case was raffled to Branch 39.
The Heirs of Rogelio P. Laudes moved for the joint trial of Land Registration Case No. N-875 and a related land registration case, Land Registration Case No. N-873, which covered a parcel of land under Plan Psu-214678.
During the joint trial before the Regional Trial Court, Branch 39, the Heirs of Rogelio P. Laudes presented lay witnesses and administrative certifications, including certifications from the Officer-In-Charge of the Community Environment and Natural Resources Office, administrative orders from the Secretary of the Department of Environment and Natural Resources, and a Land Classification Map, while the State offered no evidence.
On June 21, 2018, the Regional Trial Court, Branch 39 rendered a Joint Decision confirming and registering the titles of the lands in favor of the Heirs of Rogelio P. Laudes.
The Republic of the Philippines, represented by the Office of the Solicitor General, appealed to the Court of Appeals, arguing that the Heirs of Rogelio P. Laudes failed to prove that the lands were alienable and disposable public domain and failed to show possession since June 12, 1945, or earlier [1000].
On June 30, 2020, the Court of Appeals rendered a Decision denying the appeal of the Republic of the Philippines and affirming the Joint Decision in toto [1000].
The Court of Appeals denied the separate Motions for Reconsideration filed by the Republic of the Philippines on March 9, 2021 [1000, 1001].
The Republic of the Philippines, represented by the Office of the Solicitor General, elevated the case to the Supreme Court of the Philippines via a Petition for Review on Certiorari under Rule 45 of the Rules of Court [1001].
On January 31, 2024, the Supreme Court of the Philippines rendered a Decision partially granting the Petition and remanding the case to the Court of Appeals [994, 1015].

III. Arguments of the Parties

A. Petitioner/Prosecution (Republic of the Philippines):

The Office of the Solicitor General argues that the Heirs of Rogelio P. Laudes failed to present sufficient evidence to prove that the subject properties were classified as alienable and disposable lands of the public domain [1001].
The Office of the Solicitor General contends that the certifications issued by the Community Environment and Natural Resources Office and the Provincial Environment and Natural Resources Office, as well as the Land Classification Map, do not constitute competent and sufficient proof of land classification under the strict parameters established in Republic v. T.A.N. Properties, Inc. [1001].
The Office of the Solicitor General asserts that the Heirs of Rogelio P. Laudes failed to prove open, continuous, exclusive, and notorious possession and occupation of the subject properties under a bona fide claim of ownership since June 12, 1945, or earlier, as the evidence indicates that the predecessors-in-interest of the Heirs of Rogelio P. Laudes occupied the properties only starting in 1949 [1001].
The Office of the Solicitor General maintains that under Section 14, paragraph 1 of Presidential Decree No. 1529, the June 12, 1945 possessory threshold is mandatory and cannot be shortened by mere administrative classification of public lands [558, 1001].
The Office of the Solicitor General further argues in the Reply that the Heirs of Rogelio P. Laudes failed to satisfy the newly enacted evidentiary requirements of Republic Act No. 11573 because the Heirs of Rogelio P. Laudes did not present a geodetic engineer of the Department of Environment and Natural Resources to testify on the contents of the approved survey plan and the required certifications [1003].

B. Respondent/Defense (Heirs of Rogelio P. Laudes):

The Heirs of Rogelio P. Laudes argue that the presentation of the Community Environment and Natural Resources Office Certifications, the administrative orders of the Secretary of the Department of Environment and Natural Resources, and the Land Classification Map issued by the National Mapping and Resource Information Authority constitutes substantial compliance with the legal requirements to prove that the lands are alienable and disposable [1002].
The Heirs of Rogelio P. Laudes contend that leniency should be accorded to the applicants because the applicants merely relied on the administrative regulations and orders of the Secretary of the Department of Environment and Natural Resources [1002].
The Heirs of Rogelio P. Laudes assert that the strict evidentiary rule established in Dumo v. Republic should only be applied prospectively, as the Dumo decision was promulgated after the land registration cases had already been submitted for decision before the Regional Trial Court [1002].
The Heirs of Rogelio P. Laudes maintain that the issue of whether the applicants and the predecessors-in-interest of the applicants possessed and occupied the subject properties in the concept of owner is a question of fact that is not proper for review under a Petition for Review on Certiorari under Rule 45 [1002].

C. Common Ground:

Both the Republic of the Philippines and the Heirs of Rogelio P. Laudes do not dispute that Rogelio P. Laudes died on September 19, 1984, and that the Heirs of Rogelio P. Laudes subsequently acquired the subject properties through a sheriff's sale in 1990 to satisfy the civil liability of Jesus E. Enova.
Both parties admit that the Heirs of Rogelio P. Laudes obtained a Sheriff's Final Deed on October 16, 1991, and that the Regional Trial Court, Branch 40 issued an Order on January 5, 2000, declaring the Heirs of Rogelio P. Laudes as the true and lawful owners of the subject properties.

IV. Issues

A. MAIN ISSUE:

B. SECONDARY ISSUES:

Whether the newly enacted provisions of Republic Act No. 11573 apply retroactively to land registration applications that were already pending before the Regional Trial Court or the Court of Appeals on September 1, 2021 [1009].
Whether the Heirs of Rogelio P. Laudes established open, continuous, exclusive, and notorious possession and occupation of the subject properties for the duration required by law under the amended Section 14, paragraph 1 of Presidential Decree No. 1529.

V. Ruling / Disposition

A. RULING ON THE MAIN ISSUE:

B. RULING ON SECONDARY ISSUE NO. 1:

C. RULING ON SECONDARY ISSUE NO. 2:

VERBATIM DISPOSITIVE PORTION: The Supreme Court of the Philippines' final dispositive portion in G.R. No. 256194 is quoted verbatim as follows:

ACCORDINGLY, the Petition for Review on Certiorari filed by the Republic of the Philippines is PARTLY GRANTED .

The case is REMANDED to the Court of Appeals for reception of evidence on the subject properties' land classification status based on the parameters set forth in Section 7 of Republic Act No. 11573. The Court of Appeals is directed to resolve the case with utmost dispatch.

SO ORDERED

VI. Ratio Decidendi and Doctrines

A. Ratio Decidendi:

The Curative Nature of Republic Act No. 11573: Section 1 of Republic Act No. 11573 explicitly declares the policy of the State to simplify, update, and harmonize related provisions of land laws to provide land tenure security [1009]. Curative statutes reach back to past events to correct errors, irregularities, or technical defects to make valid what would otherwise be ineffective [1009]. Consequently, the shortened possessory period of twenty (20) years and the simplified rules on proving land classification must apply retroactively to pending applications [1009].
The Deletion of the Old Section 14(2) on Prescription: The enactment of Republic Act No. 11573 deleted the old Section 14, paragraph 2 of Presidential Decree No. 1529, which authorized registration based on acquisitive prescription under the Civil Code [60, 61, 1009]. The shortened twenty (20)-year possessory period under the new Section 14, paragraph 1 renders the longer thirty (30)-year extraordinary prescription period under the Civil Code unnecessary for land registration, allowing possessors of twenty years to register immediately without waiting for extraordinary prescription to run [61, 1009].
The Evidentiary Requirements Under Section 7 of Republic Act No. 11573: Section 7 of Republic Act No. 11573 designates a certification issued by a geodetic engineer of the Department of Environment and Natural Resources, imprinted directly on the approved survey plan, as sufficient proof of land alienability [1014]. The imprinted certification must contain a sworn statement stating the applicable Forestry Administrative Order, Department of Environment and Natural Resources Administrative Order, Executive Order, Proclamations, and Land Classification Project Map Number [1014]. If the original classification order is unavailable, the certification must state the Land Classification Map number, the Project Number, and the release date [1014].
The Requirement of Authentication for Geodetic Certifications: Certifications issued by geodetic engineers of the Department of Environment and Natural Resources do not fall under the category of public documents that are self-authenticating under Rule 132 of the Rules of Court [1014]. Thus, the designated geodetic engineer who issued the certification must be presented as a witness to verify the contents of the certification and undergo cross-examination [1014].
The Shift in the Burden of Proof: While the applicant carries the initial burden to prove that the land is alienable and disposable, the classification of public agricultural land as alienable serves as the positive act of the State abdicating the State's public dominion [1005, 1018]. Once the applicant discharges the burden of proving alienability, the burden of proof shifts to the State to show that the land is still retained for some public use or service [1018].

B. Doctrines/Rules:

The Regalian Presumption (Jura Regalia): All lands of the public domain belong to the State, and any person applying for original land registration carries the burden to overcome this presumption through clear, positive, and convincing evidence that the State has alienated or reclassified the land as private property [1004, 1018].
The Simplified Land Classification Rule: Under Republic Act No. 11573, a certification issued by a designated geodetic engineer of the Department of Environment and Natural Resources, imprinted on the approved survey plan, is sufficient proof to establish that a parcel of land is alienable and disposable, thereby superseding the strict rules in Republic v. T.A.N. Properties, Inc. [1013, 1014].
The Retroactivity of Curative Land Laws: Statutes that are curative and remedial in nature, which simplify technical procedures and expand land tenure security without impairing vested rights, must be applied retroactively to all pending land registration cases at the first instance or on appeal [1009].

C. Limitations/Exceptions:

The Twelve-Hectare Registration Limit: Under Section 6 of Republic Act No. 11573, an applicant can only apply for original land registration for parcels not exceeding twelve (12) hectares in area [1008].
Limitation on Unclassified Lands: No amount of adverse possession, regardless of the length of time, can ripen into private ownership or vest registrable title if the land has not been officially classified as alienable and disposable public domain by a positive act of the Executive Department [1005].

D. Topic Integration:

Republic v. Heirs of Rogelio P. Laudes is a landmark decision confirming the retroactive application of Republic Act No. 11573 and interpreting the new parameters for original land registration under Section 14, paragraph 1 of Presidential Decree No. 1529 [994, 1009]. G.R. No. 256194 is directly controlling for the assigned topic because the case harmonizes the shortened possessory period of twenty (20) years with the simplified evidentiary requirement for proving land classification status [1008, 1014]. While the decision rejects the old, rigid T.A.N. Properties doctrine, the case reinforces the rule that land registration applicants cannot rely on bare Community Environment and Natural Resources Office certifications, establishing that the geodetic engineer of the Department of Environment and Natural Resources must verify and authenticate the land classification on the approved survey plan under oath [1013, 1014].