G.R. No. 114734 - Imbuido vs. National Labor Relations Commission

The subject of the litigation is a parcel of land measuring 496 square meters located in Manga, Tinago, Ozamis City.
Francisco Bacus, the respondent, claimed ownership of the land and filed an application for its registration in his name with the Court of First Instance of Misamis Occidental on September 14, 1981.
The application was contested by the Republic of the Philippines through the Director of Lands, based on the ground that Bacus did not hold title to the property and that the land was still part of the public domain as forest land.

The registration court ruled in favor of Bacus, granting his application for registration despite the objections raised by the Republic.
The Republic appealed the decision, reiterating that the land remained unalienable forest land, but the appealed decision was affirmed in toto by the lower appellate court.
Following the affirmation, the dispute escalated into a petition that raised constitutional questions touching on the doctrine of separation of powers.

The Republic introduced a letter by District Forester Elpidio D. Aspiras dated April 19, 1980, which stated that the subject lot was part of Timberland Project No. 20, as certified on August 29, 1925 (BF L.C. Map No. 560).
A subsequent endorsement dated April 21, 1982 by the same district forester further confirmed that the land remained within the designated timberland block, urging opposition during the cadastral hearing.
These evidences were used to demonstrate that the land had never been declassified from its status as part of the public forests.

The City Development Coordinator of Ozamis City, who asserted that the subject land was within a commercial-residential zone.
The Register of Deeds of Ozamis City, who noted that surrounding properties had already been registered in favor of private persons.

The lower court, basing its decision on these certifications, presumed that the practical character of the land had changed, thereby dispensing with the need for an official proclamation declassifying the forest land.

The petition raised a constitutional question regarding the doctrine of separation of powers, questioning whether the judiciary could effectively alter the legal character of the property without a positive act by the appropriate executive authority.
The case highlighted that forest lands are inherently inalienable and can only be converted to alienable or disposable lands through an official and deliberate act of declassification by the President, as provided under Act No. 141 and the Revised Administrative Code.
The court expressed disapproval for relying on certifications by functionaries without jurisdiction to reclassify public lands, emphasizing that such reclassification is an act reserved for executive or legislative branches.

Whether the property in dispute, still classified as forest land, can be subject to registration in the name of a private individual.
Whether the possession of the land by Bacus, even if accompanied by improvements, amounts to a prescriptive claim that can override its status as part of the public domain.

Whether the lower courts, by relying on local certifications and circumstantial changes in land use, may effectively assume that the forest land had been declassified and was available for private appropriation.
Whether the judiciary can bypass the statutory requirement of a positive governmental act to declassify forest lands and therefore confirm an imperfect title under Section 48(b) of C.A. 141.

Whether the respondent court’s decision to change the legal status of the land, without an express act of declassification by the President or proper executive authority, constitutes an encroachment upon the powers reserved for the executive and legislative branches.
Whether the exercise of the court’s equity jurisdiction in this context violates the doctrine of separation of powers.