Judicial Confirmation of Imperfect Title

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Under the public land act, judicial confirmation of imperfect title required

possession en concepto de dueno since time immemorial, or since July 26,


1894. Under CA No. 141, this requirement was retained. However, on June
22, 1957, RA No. 1942 was enacted amending CA No. 141. This latere
enactment required adverse possession for a period of only thirty (30) years.
On January 25, 1977, the President enacted PD No. 1073, further amending
CA No. 141, extending the period for filing applications for judicial
confirmation of imperfect or incomplete titles to December 31, 1987. Under
this Decree, the provisions of Section 48 (b) and Section 48 (c), Chapter
VIII, of the Public Land Act are ehreby amended in the sense that these
provisions shall apply only to alienable and disposable land of the public
domain which have been in open, continuous, exclusive and notorious
possession and occupation by the applicant himself or thru his predecessorin-interest under bonafide claim of acquisition of ownership, since June 12,
1945. (Public Estates Authority vs. Court of Appeals, GR No. 112172,
November 20, 2000, First Division, Pardo J.)

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