Director of Lands v. Court of Appeals
REITERATIONFacts
The Antecedents: An application for the registration of 291 hectares of land was filed by the Salazar siblings, who claimed to have acquired the land from their mother, Soledad Fajardo Vda. de Salazar, who in turn purchased it from Tomas Cevallos and his sister. The land was declared alienable and disposable by the Director of Forestry only on April 28, 1961. The applicants alleged possession through their overseer, who did not testify. Procedural History: The Court of Appeals initially denied the application but later reversed its decision and granted it. The Director of Lands appealed to the Supreme Court. The Petition: The Director of Lands argued that the Court of Appeals erred in holding that courts could classify lands and in disregarding the certification of the Bureau of Forestry that the land was only declared alienable and disposable on April 28, 1961. The Director also contended that the Salazars failed to present competent evidence of their and their predecessors' continuous, uninterrupted, open, exclusive, and notorious possession in the concept of owner for more than thirty years prior to the filing of the application.
Issue(s)
Whether the 291-hectare tract of land is registerable under section 48(b) of the Public Land Law as amended by Republic Act No. 1942, considering it was declared alienable and disposable only on April 28, 1961. Whether the applicants, the Salazars, and their predecessors-in-interest proved their possession of the land in the concept of owner for at least thirty years prior to the filing of the application.
Ruling
The Supreme Court reversed and set aside the resolution of the Court of Appeals dated March 23, 1979, and affirmed its decision of August 31, 1977, dismissing the application for registration. Costs were against respondents Salazar.
Ratio Decidendi
On the registerability of the land: The Court held that the classification, delimitation, and survey of lands of the public domain are vested in the President upon recommendation of the Minister of Natural Resources. Forestal land is not registerable until it is declassified and released for agricultural purposes. The certification from the Bureau of Forestry that the land in question became alienable or disposable only on April 28, 1961, was crucial. Any possession prior to this date, when the land was still forestal, could not be credited towards the thirty-year requirement under Section 48(b) of the Public Land Law. Therefore, the land was not registerable at the time of the application. On the proof of possession: The Court found that the Salazars failed to present competent evidence to prove their alleged possession of the land in the concept of owner for the required thirty-year period. The evidence presented, such as tax declarations and receipts, was found to be irrelevant, insufficient, or contradictory. Furthermore, the testimony of the applicants' overseer, who was allegedly in possession, was not presented. The Court noted that numerous occupants, who claimed to have been born on and cultivating portions of the land for a long time, opposed the application, asserting their own rights based on long-standing occupation. The Court also pointed out discrepancies in the claimed area and boundaries of the land, suggesting an unwarranted appropriation of public domain. The Court reiterated that tax declarations and receipts are not conclusive evidence of ownership or the right to possess land when not supported by other evidence.
Main Doctrine
Possession of forestal lands cannot ripen into private ownership, and land classified as forestal cannot be registered until it is declassified and considered alienable and disposable public agricultural land.