G.R. No. 132963 - Republic vs. Doldol

In 1959, respondent Nicanor Doldol began occupying a portion of land in Barrio Pontacan, Municipality of Opol, Misamis Oriental.
On October 23, 1963, Doldol filed an application with the Bureau of Forest Development for saltwork purposes regarding the disputed area.
The application was ultimately rejected by the Director of Forestry on April 1, 1968.

In 1965, the Provincial Board of Misamis Oriental passed a resolution reserving Lot 4932, Cad-237, Opol Cadastre as a school site, which inadvertently encompassed the area occupied by Doldol.
In line with the resolution, the Opol High School transferred to the reserved site in 1970.
On November 2, 1987, then President Corazon Aquino issued Proclamation No. 180, explicitly reserving the area (including the disputed portion) for the Opol High School, which was later renamed the Opol National Secondary Technical School (hereafter Opol National School).

Opol National School, needing the area for its projects, repeatedly demanded that Doldol vacate the portion reserved for the school.
After Doldol’s refusal, in 1991 the school filed a complaint for accion possessoria with the Regional Trial Court of Cagayan de Oro.
The trial court ruled in favor of the school, ordering Doldol to vacate the land.

The Court of Appeals reversed the trial court’s decision on October 27, 1997, holding that Doldol, by exercising open, continuous, exclusive, and notorious possession for thirty-two years (from 1959 to 1991), acquired a form of ownership over the disputed area.
Opol National School’s motion for reconsideration, resolved on March 5, 1998, was denied by the Court of Appeals.
The school elevated the case to the Supreme Court, arguing that the appellate decision misapplied the law by favoring Doldol’s claim despite the conflicting reservation by Presidential Proclamation.

Whether Doldol’s thirty-two-year possession of the disputed land qualifies him for ownership under the Public Land Act, notwithstanding the reservation of the lot for Opol National School.

The issue centers on the interpretation and application of Section 48 of Commonwealth Act No. 141 (as amended by Republic Act No. 1942 and further amended by Presidential Decree No. 1073).
Specifically, it questions whether possession starting in 1959 satisfies the legal requirement of being “since June 12, 1945 or earlier” for the acquisition of title through judicial confirmation of imperfect title.

Whether the Court of Appeals erred in its application of an outdated version of Section 48 of the Public Land Act, thereby wrongfully affirming Doldol’s claim over the land in dispute.

The school contended that the appellate court overlooked the reservation of the land for public use and education.
This raises the broader question of the impact of government reservations on claims of adverse possession or right to confirm title.