G.R. No. L-58867 June 22, 1984
Lessons Applicable: Sec. 3 Art. XII 1987 Constitution (Land Titles and Deeds)
FACTS:
- Land situated in Obando, Bulacan
- May 10, 1976: The Valerianos claimed that they are the co-owners in fee simple of the land applied for partly through:
- inheritance - 1918; and
- purchase - May 2, 1958
- Republic of the Philippines, represented by the Director of the Bureau of Forest Development opposed the application on the principal ground that the land applied for is within the unclassified region of Obando, Bulacan, per BF Map LC No. 637 dated March 1, 1927; and that areas within the unclassified region are denominated as forest lands and do not form part of the disposable and alienable portion of the public domain
- Land was found to be an Unclassified Region of Obando, Bulacan per BF LC Map No. 637, certified March 1, 1927. However, on-the-spot inspection conducted by a representative of this Office, disclosed that the same was devoid of any forest growth and forms part of a well-developed and 100 percent producing fishponds. 2 houses of light materials were erected within the area for the caretakers temporary dwelling.
- CA Affirmed RTC: in favor of the Valerianos
ISSUES:
- W/N the Courts can reclassify public land - NO
- W/N the Valerianos are entitled to judicial confirmation of title - NO
HELD: CA reverse
- NO
- In effect, what the Courts a quo have done is to release the subject property from the unclassified category, which is beyond their competence and jurisdiction
- The classification of public lands is an exclusive prerogative of the Executive Department of the Government and not of the Courts.
- In the absence of such classification, the land remains as unclassified land until it is released therefrom and rendered open to disposition.
2. NO
- Regalian doctrine: all lands of the public domain belong to the State, and that the State is the source of any asserted right to ownership in land and charged with the conservation of such patrimony.
- if land is w/in the jurisdiction of the Bureau of Forest Development, it would be beyond the jurisdiction of the Cadastral Court to register it under the Torrens System
- Since the subject property is still unclassified, whatever possession Applicants may have had, and, however long, cannot ripen into private ownership
- The conversion of subject property into a fishpond by Applicants, or the alleged titling of properties around it, does not automatically render the property as alienable and disposable.
- Applicants' remedy lies in the release of the property from its present classification
- . In fairness to Applicants, and it appearing that there are titled lands around the subject property, petitioners-officials should give serious consideration to the matter of classification of the land in question.
