G.R. No. 83609 - Director of Lands vs. Court of Appeals

Petitioners Ibarra and Amelia Bisnar filed a joint application for registration of title to two parcels of land, Lots 866 and 870 of Pilar Cadastra, Plan AP-06-000869.
The parcels contain 28 hectares (284,424 sq.m.) and 34 hectares (345,385 sq.m.), respectively, situated in Barrio Gen. Hizon, Municipality of President Roxas, Province of Capiz.
The applicants alleged ownership through inheritance and claimed to have paid taxes on the land. The joint application was filed on July 20, 1976.

On December 16, 1976, the Director of Lands and Director of the Bureau of Forest Development opposed the application on several grounds:

Neither the applicants nor predecessors had sufficient title to acquire fee simple ownership as no recognized Spanish-era title or other modes of title acquisition applied.
They did not possess the land for at least thirty (30) years in an open, continuous, exclusive and notorious manner.
The lands were portions of the public domain and were not subject to private appropriation.

On February 24, 1977, the applicants amended the application to allege possession under Chapter 8, Commonwealth Act 141, as amended, for over fifty (50) years.

The trial court found that applicants and predecessors-in-interest had open, public, continuous, peaceful, and adverse possession under bona fide claim of ownership for more than eighty (80) years, exceeding the 30-year requirement.
The court observed that improvements were introduced on the land, such as planting coconuts, bamboos, and the conversion of part of the land into productive fishponds.
Consequently, the trial court ordered registration of the titles in their favor.

The Court of Appeals affirmed the trial court's ruling.
It held that classification of the parcels as timberland by the Director of Forestry could not prevail in the absence of proof that the lands were more valuable as forest land than agricultural land.
Cited the case of Ankron v. Government of the Philippine Islands to support this view.

Classification or reclassification of public lands into alienable or disposable agricultural land, mineral land, or forest land is an exclusive prerogative of the Executive Department, not the courts.
Possession of forest lands, regardless of duration, cannot ripen into private ownership.
The applicant for registration bears the burden of proving compliance with Section 48 of Commonwealth Act No. 141, as amended.

Whether the lots in question can be registered under Section 48(b) of Commonwealth Act No. 141, as amended.
Whether the Court of Appeals erred in affirming the registration of titles over lands classified as forest lands or timberland.
Whether possession of forest lands can ripen into private ownership, regardless of length of possession.
Whether the classification or reclassification of public lands is a judicial or executive function.
Whether the applicants sufficiently met the burden of proof required for registration under the applicable law.