Facts:

• The case involves the Republic of the Philippines (petitioner) and Celestina Naguiat (respondent) regarding the registration of title to four parcels of land in Panan, Botolan, Zambales.
• Naguiat filed the application on December 29, 1989, with the Regional Trial Court (RTC) of Zambales, Branch 69.
• She claimed ownership by purchase from LID Corporation, which acquired it from Demetria Calderon, Josefina Moraga, and Fausto Monje, who had possessed the land for over 30 years.
• The Republic opposed the application on June 29, 1990, arguing that neither Naguiat nor her predecessors had been in open, continuous, exclusive, and notorious possession since June 12, 1945, or earlier.
• The Republic also contended that the land was part of the public domain and not subject to private appropriation.
• The RTC issued an order of general default against all except the Solicitor General and proceeded with the hearing.
• On September 30, 1991, the RTC ruled in favor of Naguiat, adjudicating the parcels of land to her and ordering their registration.
• The Republic's appeal to the Court of Appeals (CA) was dismissed, leading to the present petition for review before the Supreme Court.

Issue:

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Ruling:

• The Supreme Court granted the petition, reversing and setting aside the CA's decision.
• The application for origin...(Unlock)

Ratio:

• The Supreme Court emphasized that public forest lands or forest reserves are not capable of private appropriation unless declassified and released by a positive act of the government to form part of the disposable agricultural lands of the public domain.
• The classification of land as forest land does not change merely because it has been stripped of its forest cover.
• The presumption that land is part of the public domain remains unless incontrovertible evidence is presented to show that it has b...continue reading