Republic v. Court of Appeals
REITERATIONFacts
The Antecedents: This case concerns two applications for the original registration of two parcels of land located in the barrio of Umnas, Municipality of Vintar, Province of Ilocos Norte. The applications were filed by private respondents Jose Arquillo, Pastor Valdez, Nicolas Manayan, German Manayan, Clemente Manayan, Salvacion D. Arquillo, and Cosme Daguio. The Director of Lands and the Director of Forestry opposed these applications, asserting that the lands were part of the public domain and, in part, within a declared forest reserve. The Director of Lands also contended that the applications were filed after the statutory deadline for availing of certain provisions of the Public Land Act. Procedural History: The two applications for land registration were heard jointly. The trial court, after establishing jurisdictional facts and issuing an order of general default, rendered a decision on December 13, 1972, in favor of the applicants, ordering the registration of the parcels. The Director of Lands and the Director of Forestry appealed this decision. Subsequently, a motion for a new trial was granted for LRC Case No. 125, leading to a new decision on November 20, 1973, again adjudicating the land to the applicants. The records were elevated to the Court of Appeals, which, on November 22, 1982, affirmed the trial court's decision. The appellate court noted that the Bureau of Forestry had failed to perfect its appeal in LRC No. 125, rendering that portion of the decision final. The appeal considered by the Court of Appeals was primarily that of the Bureau of Lands in both cases and the Bureau of Forestry in LRC No. 126. The Petition: The Republic of the Philippines, represented by the Director of Lands and Director of Forest Development, filed the instant appeal by certiorari with the Supreme Court. The petitioner argues that the Court of Appeals erred in allowing the titling of lands that are part of a forest reservation and are therefore inalienable. Furthermore, the petitioner contends that the conditions for confirming imperfect titles, as laid down by law and jurisprudence, were not met. The petition specifically prays for the dismissal of the private respondents' applications for original registration, asserting that the evidence presented by the petitioner positively proved the parcels in question are within the forest reserve established under Presidential Proclamation No. 338.
Issue(s)
Whether the Court of Appeals erred in allowing the titling of lands which are part of a forest reservation. Whether the Court of Appeals erred in allowing the titling of land through confirmation of alleged imperfect title when the conditions laid down by law and jurisprudence have not been complied with. Whether the failure of the Bureau of Forestry to file a notice of appeal in LRC No. 125 rendered the decision final and executory as to it.
Ruling
The petition is DENIED. The decision of the respondent Court of Appeals is AFFIRMED.
Ratio Decidendi
On the issue of titling lands within a forest reservation: The Court reiterated the settled rule that forest lands or forest reserves are not capable of private appropriation and possession thereof, however long, cannot convert them into private property. However, the Court found that the petitioner's allegation that the parcels sought to be registered are within the Northern Ilocos Norte Forest Reserve has not been clearly established. The evidence presented by the Bureau of Forestry, particularly the report of Forest Warden Pedro Barreras, was found to be insufficient and contradictory. The witness admitted his incompetency in relating the lots applied for registration as within the Presidential Proclamation and was unsure whether the delineated portions were covered by the technical descriptions in the proclamation. The Court emphasized that the burden of proof rests on the party asserting an affirmative allegation, and the petitioner failed to substantiate its claim with convincing proof. The Court also noted that Executive Proclamation No. 338 itself provides that it shall be subject to private rights, and having been issued in 1938, it cannot despoil vested rights acquired prior to its issuance. On the issue of confirming alleged imperfect title: The Court found sufficient evidence on record showing that the parcels of land applied for are alienable and disposable and have been in the possession of the applicants and their predecessors-in-interest since time immemorial. The Court noted that the Bureau of Lands itself, by disapproving the group settlement subdivision plan (Gss-366) and recognizing the lands covered by Psu-169307 and Psu-169308 as alienable and disposable, implicitly admitted that these lands had become private property. Furthermore, the Court highlighted that the possession of the applicants commenced "since time immemorial," which predates the issuance of Presidential Proclamation No. 338 in 1938. Even if the land were within the forest reserve, private respondents' rights, having intervened prior to the classification, could not be prejudiced. The Court cited Ankron v. Government of the Philippine Islands for the principle that private interests that have intervened before a reservation is made must be recognized. On the failure to file a notice of appeal: The Court held that the failure of the petitioner Bureau of Forestry to file a notice of appeal with the trial court was not fatal. It reiterated the consistent pronouncement of the Supreme Court that estoppel does not lie against the Republic or its government. Citing Republic vs. Aquino and Luciano vs. Estrella, the Court stated that the government is usually not estopped by mistake or error on the part of its officials or agents. Therefore, the appeal by the Republic was considered validly filed and the issues were properly addressed.
Main Doctrine
Possession of forest lands, however long, cannot convert them into private property. The burden of proving that land is alienable and disposable rests on the applicant, but the government must present convincing proof that land is forest land if it opposes registration. Private rights that have intervened prior to the classification of land as forest reserve must be recognized.