Title
Bureau of Forestry vs. Court of Appeals
Case
G.R. No. L-37995
Decision Date
Aug 31, 1987
Applicant sought land registration; government opposed, citing public domain. Supreme Court ruled: 11.1863 hectares registrable as agricultural, 19.4080 hectares inalienable forest land, affirming Executive's land classification authority.

Case Digest (G.R. No. 187883)
Expanded Legal Reasoning Model

Facts:

  • Background and Procedural History
    • The case involves a petition for review on certiorari filed by the Bureau of Forestry, Bureau of Lands, and Philippine Fisheries Commission against the Court of Appeals’ decision.
      • The decision under review was rendered in CA-G.R. No. 38163-R, affirming an earlier decision of the Court of First Instance of Iloilo (Land Registration Case No. N-506, G.L.R.O. Record No. N-20783).
      • The trial court’s decision (dated April 6, 1966) ordered the registration of certain lots in favor of Filomeno Gallo, a legal-age, widower Filipino citizen.
    • The petition also raises the issue of the respondent court’s resolution (dated December 14, 1973) denying the petitioners’ motion for reconsideration, prompting the present certiorari petition.
  • Factual Background on the Land and Registration
    • On July 11, 1961, an application for registration covering four parcels of land (approximately 30.5943 hectares) situated in Buenavista, Iloilo was filed by Mercedes Diago.
      • Diago claimed occupation of the land, asserting that she had acquired it from the testate estate of the late Jose Ma. Nava, who in turn had bought it from Canuto Gustilo in 1934.
      • The Director of Lands opposed the application on the basis that neither the applicant nor her predecessors could satisfy the requirements under the Torrens system.
    • The opposition raised by the Director of Forestry:
      • Asserted that a specific portion (approximately 194,080 square meters) of the land comprised mangrove swamps.
      • Cited that this portion belonged to Timberland Block “B” (L.C. Project No. 38, L.C. Map No. 1971) of Buenavista, Iloilo, and was needed for forest purposes.
    • Subsequent developments:
      • On June 30, 1965, Filomeno Gallo purchased the subject parcels from Mercedes Diago and substituted in her place via an amended application, which reiterated the original allegations.
      • On August 30, 1965, the Philippine Fisheries Commission substituted for the Bureau of Forestry as oppositor for a portion of the land, due to the transfer of supervision and control over that area.
    • The trial court’s decision (April 6, 1966):
      • Ordered the registration of the land parcels in favor of Filomeno Gallo while excluding a portion identified as Lot “1-A” (site of the municipal hall) and subjecting some lots to a 15-meter road right-of-way.
      • Recognized that out of the total area, 11.1863 hectares (coconut lands) were within the disposable portion of the public domain, while 19.4080 hectares (identified as parcels A, A-1, A-2, and A-3) became the center of controversy regarding their classification.
  • Central Dispute on Land Classification
    • The petitioners argued that the classification of the disputed 19.4080 hectares—as forest lands or part of the public domain—was indisputable.
      • They underscored that the area was within Timberland Block “B” as per L.C. Project No. 38 and had been certified on February 18, 1956, by the then Director of Forestry as needed for forest purposes.
    • In contrast, the respondent court ruled on the basis of possession and cultivation without taking into account:
      • The certification by the Director of Forestry.
      • The established classification as forest lands, which under Philippine law are inalienable and not subject to registration.
    • Additional contentions:
      • Respondents contended that the disputed lands had been in open, continuous, and adverse possession, thereby meeting the requirements for prescription.
      • Petitioners rebuffed this by asserting that public lands, especially forest lands, cannot give rise to private ownership through prescription.
  • Arguments on the Issue of Classification
    • Petitioners’ main argument:
      • The court erred in entertaining the issue of whether lands classified as public domain (forest or agricultural) could be reclassified based solely on the evidence of possession and cultivation.
      • They maintained that the determination of land classification rests exclusively with the Executive Branch of the Government—specifically, the Office of the President (under Sec. 6 of Commonwealth Act No. 141).
    • Respondents’ argument:
      • Contended that the trial court’s determination relied on evidentiary facts showing long possession and cultivation.
      • Argued that such evidence justified treating the land as agricultural and registrable despite its classification as forest land.

Issues:

  • Whether the court has the authority to alter or vary the Executive Branch’s classification of lands of the public domain (i.e., distinguishing between agricultural, forest, or mineral lands) based on evidentiary submissions regarding possession and cultivation.
    • Does long-term possession and cultivation by private parties serve to overcome a pre-existing classification by the Director of Forestry?
  • Whether the disputed portions of the subject land, particularly the 19.4080 hectares identified as parcels A, A-1, A-2, and A-3, are subject to registration under the Torrens system or must remain inalienable as forest lands.
    • Does the certification by the Director of Forestry (dated February 18, 1956) definitively establish the land as forest land beyond the court’s power to reclassify?
  • Whether private respondents may claim title by prescription on public land and, if so, under what circumstances such possession may ripen into private ownership.
    • The further question of whether possession of forest lands, regardless of the duration, could lead to acquired private ownership under the law.

Ruling:

  • (Subscriber-Only)

Ratio:

  • (Subscriber-Only)

Doctrine:

  • (Subscriber-Only)
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