G.R. No. 172607 - People vs. Umanito

The subject property was originally part of the Hacienda de Maricaban, owned by Dolores Casal y Ochoa and documented under Original Certificate of Title (OCT) No. 291 issued in 1906.
During the American colonial period, the government acquired Maricaban, converting parts of it into military reservations. This was evidenced by the cancellation of OCT No. 291 and the issuance of Transfer Certificate of Title (TCT) No. 192 in the name of the USA.
Over subsequent years, further transfers and cancellations occurred (e.g., TCT Nos. 1218, 1219, 1688, 2288), culminating in the Philippines formally receiving the territory in 1956 and the issuance of TCT No. 61524 in 1958 under the Republic’s name.
Subsequent presidential proclamations—first under President Garcia (Proclamation No. 423) and later under Presidents Marcos (Proclamation No. 2476) and Aquino (Proclamation No. 172)—affected the classification and disposition of the land, ultimately reserving certain portions for military and public service purposes.

Dream Village claimed to represent over 2,000 families who had occupied a 78,466-square meter lot in Western Bicutan, Taguig City continuously, exclusively, and notoriously since 1985.
The association argued that despite their long-term occupation and improvements—including the construction of durable houses, roads, drainage, and communal facilities—the land was not part of the patrimonial property managed by the Bases Conversion and Development Authority (BCDA).
They maintained that the affected lot should be declared alienable and disposable, allowing its conversion through the processing of sales patent applications under Republic Acts Nos. 274 and 730.

Respondent BCDA asserted title to Fort Bonifacio, having acquired the property from previous government titles and cancellations under R.A. No. 7227, which explicitly provided for the sale of certain military reservations to raise capital for conversion projects.
On receiving a complaint from Dream Village on November 22, 1999, the Commission on the Settlement of Land Problems (COSLAP) initiated its standard mediation process to address the issue, including the conduct of a relocation/verification survey.
The DENR, through its technical director, submitted a verification survey report which found that the occupation by Dream Village was outside Lot 1 of the designated survey plan (SWO-13-000298) and instead fell within Lots 10, 11, and part of Lot 13 of SWO-00-0001302—territory held by the BCDA.
COSLAP, based on the survey findings, resolved that the subject property was outside of the BCDA-titled area and directed the Land Management Bureau (LMB) to process the sales patent applications for the occupants accordingly.

In its answer, the BCDA questioned the jurisdiction of COSLAP to decide the matter and maintained that the disputed land, being part of a titled and patrimonial government property, could not be the subject of a petition for classification or subdivision by its occupants.
The BCDA criticized the conduct of the verification survey, arguing that its representatives were not present and that the survey report was erroneous in stating the spatial boundaries of the land.
The Court of Appeals (CA) later ruled (on September 10, 2009) that COSLAP lacked jurisdiction to resolve the dispute, primarily because the matter involved a private title and a government-held estate rather than a public domain issue.
Dream Village’s motion for reconsideration was denied by the CA on July 13, 2010, prompting a petition for review on certiorari to the Supreme Court.

Dream Village's petition for review challenged the CA’s ruling on two main grounds: (A) the annulment of the COSLAP resolution was argued to be inconsistent with applicable law and precedents, and (B) the CA’s conclusion that COSLAP lacked jurisdiction was erroneous.
The petition emphasized the community’s long-standing occupation and argued that the resolution ordering the processing of sales patent applications should be enforced, despite assertions by the BCDA regarding its title over Fort Bonifacio.

Whether COSLAP had the authority to assume jurisdiction and resolve the dispute involving the classification and disposition of the subject property.
Whether COSLAP could decide on a matter involving property titled and controlled by the BCDA as opposed to lands in the public domain or those subject to free patent applications.

Whether the lot occupied by Dream Village falls within the areas declared alienable and disposable under Proclamations Nos. 2476 and 172.
Whether the attempted acquisition of title by prescription (or adverse possession) is applicable to a property registered under the Torrens system and reserved for public use.

Whether the COSLAP resolution ordering the LMB to process sales patent applications was legally sound given the limitations of its jurisdiction.
The impact of the verification survey findings on resolving the disputed boundaries, title, and the rightful disposition of the land.