Republic of the Philippines v. Apostolita San Mateo

In a petition to register a land, both CENRO certification and approval thereof by the DENR Secretary are required to be presented as proofs that the land is alienable.

G.R. No. 203560, 10 November 2014

A petition to register a land was denied for failure to present both CENRO certification and approval thereof by the DENR Secretary. As held by the Supreme Court, “a CENRO certification that a certain property is alienable, without the corresponding proof that the DENR Secretary had approved such certification, is insufficient to support a petition for registration of land. Both certification and approval are required to be presented as proofs that the land is alienable. Otherwise, the petition must be denied.”

The cited case of Republic v. Vega, which granted a petition for registration despite the absence of a DENR Certification was pro hac vice. Continue reading here.