Facts:

• The case involves the Director of Lands, the Director of Forestry, and the Republic of the Philippines as petitioners against Hon. Juan P. Aquino, Judge of the Court of First Instance of Abra, and Abra Industrial Corporation (AIC) as respondents.
• The dispute concerns a limestone-rich 70-hectare land in Bucay, Abra, with 66 hectares claimed by the petitioners as part of the Central Cordillera Forest Reserve.
• AIC, aiming to establish a cement factory, claims ownership of the entire 70 hectares based on survey plans PSU-217518, PSU-217519, and PSU-217520, valued at P6,724.48.
• On September 23, 1965, AIC filed for land registration, asserting possession since July 26, 1894.
• The application was set for hearing, with only the Director of Lands opposing it; the court issued a default order against all others.
• After AIC presented its case, the provincial fiscal opposed the application, arguing AIC lacked a registerable title and that the land remained classified as forest land.
• On July 22, 1966, the lower court ruled in favor of AIC, stating the opposition was unfounded as the Bureau of Forestry did not object to the land's exclusion from the forest reserve.
• The Director of Lands filed a motion for reconsideration, which was denied, leading to a late petition for certiorari that was dismissed.
• The Republic of the Philippines, through the Solicitor General, then filed a petition for review, alleging AIC committed actual fraud by including forest reserve land in its application, which was also denied by the lower court.

Issue:

• (Unlock)

Ruling:

• The Supreme Court ruled that the lower court erred in granting AIC's application for land registration, as the land was part of the Central Cordillera Forest Reserve and could not be privately appropriated.
• The Court also ruled that the lower court's denial of the petit...(Unlock)

Ratio:

• The Supreme Court emphasized that forest lands or reserves are inalienable and cannot be privately owned, a principle rooted in the regalian doctrine in the 1987 Constitution.
• Article XIII, Section 2 states that all lands of the public domain, including forests and natural resources, are owned by the State and cannot be alienated, except for agricultural lands.
• The classific...continue reading