Title
Collado vs. Court of Appeals
Case
G.R. No. 107764
Decision Date
Oct 4, 2002
Petitioners sought registration of land claimed as alienable, but failed to prove public domain exclusion; court annulled trial decision, retaining land as inalienable.
dispute
registration
parcel of land

Case Summary (G.R. No. 151932)

Factual Background

Petitioners sought registration of a parcel described as Lot Psu-162620, an area of approximately 120.0766 hectares situated in Barangay San Isidro (formerly Boso-boso), Antipolo, Rizal, which petitioners alleged they and their predecessors had occupied since time immemorial and in the concept of owners. The application, originally filed by Edna T. Collado on April 25, 1985 and later amended to include multiple co-applicants, attached a technical description signed by Robert C. Pangyarihan of the Bureau of Lands which expressly stated that "this survey is inside IN-12 Mariquina Watershed." Petitioners adduced testimony and documentary evidence tracing possession and transfers among predecessors-in-interest back to Sesinando Leyva, who had the property surveyed in his name in 1902, and submitted tax declarations and deeds of sale in support of successive transfers down to petitioners.

Procedural History

Oppositions were filed by the Republic through the Solicitor General and by the Municipality of Antipolo, among others. The land registration court entered an order of general default against the world except the oppositors, conducted hearings at which the oppositors largely failed to present evidence, and after submissions considered the case submitted for decision twice. The court issued a judgment on January 30, 1991 confirming petitioners' imperfect title and later directed the Land Registration Authority to issue the decree of registration. The Solicitor General filed a petition for annulment of judgment in the Court of Appeals on August 6, 1991 under Section 9(2) of B.P. Blg. 129, and the Bockasanjo ISF Awardees Association, Inc. moved to intervene before the Court of Appeals on November 29, 1991.

Trial Court Ruling

The land registration court found that petitioners had established actual, open, public and notorious possession in the concept of owners, supported by witness testimony, tax declarations, cultivation, and historical surveys and transfers. The court rejected the argument that the Lot’s alleged inclusion in the Marikina Watershed Reservation barred registration, observing that presidential proclamations were subject to existing private rights and that petitioners had presented a Bureau of Forest Development certification and other materials indicating exclusion from the watershed by Proclamation No. 1283 and amendment by Proclamation No. 1637.

Court of Appeals Ruling

The Court of Appeals granted the Republic’s petition and declared the land registration court’s decision null and void. The appellate court applied the Regalian Doctrine, held that lands of the public domain presumptively belong to the State, and stressed that a positive executive act is required to declassify public land and make it alienable and disposable. It relied on the technical description attached to the application, the earlier identification of the Lot as inside the Marikina Watershed, and reports from land administration agencies. The Court of Appeals concluded that jurisdiction over disposition of watershed lands lies with the Director of Lands subject to the Secretary of Natural Resources and that the land registration court lacked jurisdiction to adjudicate title to land within a forest or watershed reservation.

Issues Presented to the Supreme Court

Petitioners contended that the Court of Appeals erred in reversing the trial court’s confirmation of title; that the Court of Appeals improperly entertained the Republic’s petition for annulment of judgment filed after the trial court decision allegedly became final and executory; and that the Court of Appeals erred in admitting the intervention of the ISF awardees as untimely.

Legal Doctrine on Public Domain and Regalian Principle

The Court reviewed the historical and constitutional foundations of the Regalian Doctrine, tracing its pedigree from Spanish laws and subsequent Philippine legislation, and affirmed that under the 1987 Constitution all lands of the public domain and natural resources belong to the State. The Court reiterated that classification and reclassification of public lands are executive acts, and that the possession of forest lands or watershed reservations cannot ripen into private ownership by mere occupancy, since inalienable public lands are excluded from the operation of acquisitive prescription.

Application of Section 48 of Commonwealth Act No. 141

The Court reiterated the statutory requirements of Section 48 of Commonwealth Act No. 141, as amended by RA 1942 and later by P.D. 1073, for judicial confirmation of imperfect title: the applicant must show that the land is alienable and disposable and that possession was open, continuous, exclusive and notorious for the requisite period, which the Court treated as a thirty-year period under the prevailing law at the time of filing. The Court found petitioners could not satisfy those requirements because either their possession was far short of thirty years prior to the 1904 reservation or any post-reservation possession could not be counted against government classification as a watershed.

Proclamations and Land Classification

The Court examined the sequence of executive proclamations and their effect on the Lot’s status. Executive Order No. 33 (July 26, 1904) established the Marikina Watershed Reservation and thus rendered included lands inalienable. Proclamation No. 1283 (June 21, 1974) purported to exclude portions from EO 33 for townsite purposes, and Proclamation No. 1637 (April 18, 1977) later amended Proclamation No. 1283 and, according to records and the DENR Secretary’s memorandum, reverted certain areas back to watershed coverage. Later, Proclamation No. 585 (June 5, 1990) excluded portions of the watershed for the Integrated Social Forestry Program and placed them under DENR stewardship. The Court held that a positive act of the Executive is required to declassify a watershed reservation and that conflicting or uncertain documentary materials do not suffice to displace the presumption that the land remains part of the reservation.

Evaluation of Evidence

The Court weighed petitioners’ evidence, including tax declarations, historical surveys and a Bureau of Forest Development certification allegedly verifying exclusion from the watershed, against official reports and letters from land administration agencies and the technical description attached to petitioners’ own application which stated that the Lot was inside the Marikina Watershed. The Court found the evidence insufficient to show clear and convincing proof of declassification or that petitioners’ possession met the statutory period required under Section 48. The Court emphasized that even if Proclamation No. 1283 had excluded the area in 1974, petitioners’ possession counted from that date would be only eleven years by the filing of their application in 1985, and thereafter Proclamation No. 1637 and Proclamation No. 585 affected the classification and status of the land.

Annulment Petition and Jurisdictional Consequences

Addressing the contention that the Republic’s petition for annulment of judgment was filed too late, the Court held that procedural irregularities w

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