G.R. No. 13298 - Ramos vs. Director of Lands

Background of Land and Title
Restituto Romero y Ponce occupied a tract in San Jose, Nueva Ecija, from 1882 and obtained a possessory information title under the Royal Decree of February 13, 1894, registered February 8, 1896.
Parcel No. 1 (Exhibit A) was included in Romero’s title and sold in February 1907 to Cornelio Ramos and his wife, Ambrosia Salamanca.

Registration Proceedings and Trial Court Decision
Ramos instituted registration proceedings before the Court of First Instance of Nueva Ecija to confirm his title to Parcel No. 1.
The Director of Lands objected that the Spanish possessory title was invalid; the Director of Forestry objected that Parcel No. 1 was public forest land.
The trial court sustained both objections and denied registration of the larger portion of Parcel No. 1 (marked A, B, and C on Government Plan, Exhibit 1).

Whether Ramos’s color of title and open, continuous, exclusive, and notorious possession under subsection 6, section 54 of Act No. 926 (as amended by Act No. 1908) entitle him to registration of the entire Parcel No. 1.
Whether partial cultivation (about one-fourth) constitutes constructive possession of the entire tract.
Whether the land qualifies as “agricultural public land” under the Public Land Law and the Philippine Bill.

Whether the trial court erred in excluding Parcel No. 1 from registration in the absence of conclusive proof that it is forest land.