Case Summary (G.R. No. 83609)
Facts and Procedural History
Respondents Ibarra and Amelia Bisnar applied for registration of two parcels of land, Lots 866 and 870 of Pilar Cadastra, covering approximately 62 hectares in total. They claimed ownership in fee simple by inheritance and asserted continuous possession and tax payments. The Director of Lands opposed, arguing the parcels were part of the public domain under forest classification and that neither the applicants nor their predecessors held lawful title under recognized modes such as royal grants or purchase titles. The applicants amended their petition to invoke the benefits of Section 48, Chapter 8, Commonwealth Act (CA) No. 141, claiming over 50 years of possession. The trial court granted registration based on findings of long, peaceful, and adverse possession with improvements. The Court of Appeals affirmed, rejecting the Director of Forestry's timberland classification absent proof of superior forest value.
Issues on Appeal
- Whether classification or reclassification of public lands is a judicial or executive function.
- Whether long possession of forest lands can confer private ownership.
- Whether the applicants met the burden of proof under Section 48 of CA 141 for registration.
Executive versus Judicial Authority on Land Classification
The Supreme Court reaffirmed the doctrine that classification or reclassification of public lands into alienable or disposable agricultural land, mineral land, or forest land is an exclusive prerogative of the Executive Department, specifically through the Office of the President. Courts lack jurisdiction to alter such classification. This principle was established under Section 6 of CA 141 and further confirmed in Bureau of Forestry v. Court of Appeals. Consequently, the Court of Appeals erred in disregarding official certifications that the lots in question were forest lands and needed for forest purposes.
Effect of Forest Land Classification on Ownership Claims
The Court emphasized that forest lands remain under the exclusive jurisdiction of the Bureau of Forestry and cannot be subject to private ownership, regardless of the duration of possession. Possession, even if continuous and adverse for decades, does not transform forest lands into alienable property. Declassification or release from forest status into alienable agricultural land requires a formal proclamation by the government. Without such executive action, claims for title registration based on possession under Section 48 of CA 141 do not apply. The Court cited prior rulings holding that possession of forest lands cannot ripen into ownership and that cadastral courts lack jurisdiction to register titles over forest lands.
Burden of Proof Under Section 48 of CA 141
Applicants for confirmation and registration of imperfect titles bear the burden of proof to establish:
- The land is public agricultural land (not forest land).
- They or their predecessors-in-interest have possessed the land openly, continuously, exclusively, and adversely for at least t
Case Syllabus (G.R. No. 83609)
Case Background and Procedural History
- The petitioner, Director of Lands, through the Solicitor General, seeks a review of the Court of Appeals decision dated May 27, 1988, in CA-G.R. CV No. 66426, which affirmed the ruling of the Court of First Instance of Capiz.
- The trial court had granted the private respondents, Ibarra and Amelia Bisnar, confirmation and registration of title to two parcels of land under LRC Cad. Rec. 1256.
- The Bisnars' joint application for title registration was filed on July 20, 1976, claiming ownership in fee simple of Lots 866 and 870 of Pilar Cadastra, Plan AP-06-000869.
- The parcels encompass approximately 28 hectares (284,424 sq.m.) and 34 hectares (345,385 sq.m.), respectively, located in Barrio Gen. Hizon, Municipality of President Roxas, Province of Capiz.
- The applicants claimed these lands by inheritance and alleged continuous tax payment on the properties.
- The Director of Lands and Director of the Bureau of Forest Development opposed the application on December 16, 1976, asserting insufficient title, lack of possession requirements, and classification as public domain forest land not subject to private ownership.
- An amended application was filed by the applicants on February 24, 1977, and approved on March 14, 1977, including an alternative request under Chapter 8, Commonwealth Act 141, claiming possession for over 50 years.
- The trial court ruled in favor of the Bisnars, finding over eighty (80) years of open, public, continuous, peaceful, and adverse possession coupled with land improvement and conversion into productive uses.
- The Court of Appeals affirmed the trial court's decision, dismissing the government's classification of the land as timberland due to lack of proof that it was more valuable as forest than agricultural land.
Opposition by the Government and Legal Grounds
- The Director of Lands contended that:
- The classification or reclassification of public lands into alienable or disposable agricultural land, mineral land, or forest land is an exclusive prerogative of the Executive Department, not the courts.
- Possession of forest lands, regardless of duration, cannot mature into private ownership.
- Applicants for title registration bear the burden of