Facts:

• In April 1941, Canas Plantation Company purchased approximately 600 hectares of public land in Basilan from the Government.
• The company complied with the Public Land Law and paid the total price for the land.
• The last installment of P8,102.94 was paid using Japanese military notes during the Japanese occupation.
• On August 17, 1948, the Director of Lands ordered the issuance of a patent for the land, followed by the issuance of sales patent No. V-166 two days later.
• This patent led to the issuance of original certificate of title No. P-6 in the name of Canas Plantation Company.
• The patent and title included two conditions:
  • The Republic of the Philippines held a first lien on the land for P8,102.94, payable to the Bureau of Lands if the Japanese payment was invalidated.
  • A portion of the land designated as timber land (Block A of Zamboanga Project No. 12, 199.68 hectares) would remain with the Government.
• On May 25, 1951, Canas Plantation Company filed a petition in the Court of First Instance of Zamboanga to cancel these restrictions.
• The company argued that payments made during the Japanese regime were validated by the courts and that the second condition was invalid.
• The Bureau of Forestry objected to the court's jurisdiction, claiming the land was still public domain.
• The court upheld the objection and dismissed the petition, leading to an appeal by Canas Plantation Company.

Issue:

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Ruling:

• The Supreme Court reversed the decision of the Court of First Instance of Zamboanga, confirming that the lower court had jurisdiction over the case.
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Ratio:

• The Supreme Court reasoned that once the patent and certificate of title were issued to Canas Plantation Company, the land was no longer classified as part of the public domain.
• The issuance of a patent ...continue reading