G.R. No. 193657 - Republic vs. Heirs of Daquer

On October 22, 1933, Ignacio Daquer, married to Fernanda Abela, filed Homestead Application No. 197317 for nine hectares (90,000 sq. m.) of public land in Brgy. Corong-Corong, Bacuit, Palawan, for “exclusive personal use and benefit.”
On September 3, 1936, by authority of the Director of the Bureau of Lands, the Provincial Environment and Natural Resources Officer approved Daquer’s application and issued Homestead Patent No. V-67820 covering 65,273 sq. m.
The homestead patent was registered at the Palawan Register of Deeds and Original Certificate of Title (OCT) No. G-3287 was issued in Daquer’s name.
Daquer died on April 3, 1969, survived by his children Porcepina Daquer Aban, Alita Daquer Quijano, and Neria Daquer Laguta (collectively, the Heirs of Daquer).

Following directives from the DENR Secretary and Undersecretary (circa 2000) to inventory spurious titles, CENRO Taytay Land Management Officer Mariano Lilang, Jr. investigated Lot No. H-19731.
On July 10, 2000, Lilang and Senior Forest Management Specialist Leonardo Publico issued a certification confirming the lot remained within the “Unclassified Zone” (unclassified public forest) under Land Classification Map No. 1467 (certified 1941).
On April 1, 2003, the Republic of the Philippines filed a Complaint for Cancellation of Free Patent, Cancellation of OCT No. G-3287, and Reversion of land to the public domain, alleging the lot was inalienable forest/timberland at grant.
Trial Court (Branch 95, RTC Puerto Princesa City) denied the Republic’s complaint on September 28, 2007, invoking presumption of regularity of the patent and presuming unclassified lands to be agricultural.
The Court of Appeals, in CA-G.R. CV No. 90488, affirmed the RTC Decision on January 14, 2010 and denied reconsideration on September 7, 2010.
The Republic petitioned the Supreme Court under Rule 45, raising two central issues concerning classification by patent issuance and alleged jurisdictional defect in Homestead Patent No. V-67820.

Whether the mere issuance of a homestead patent can reclassify an otherwise unclassified public land into an alienable and disposable agricultural land of the public domain.
Whether the issuance of Homestead Patent No. V-67820 was jurisdictionally defective because Lot No. H-19731 was still inalienable public domain (unclassified forest/timberland) when the patent was granted.