Spouses Villarico v. Court of Appeals
REITERATIONFacts
The Antecedents: Spouses Teofilo and Maxima Villarico filed an application for confirmation of title over a 1,834 square meter parcel of land in Meycauayan, Bulacan. They claimed ownership by purchase from Teofilo's parents, Segundo Villarico and Mercedes Cardenas, and asserted open, adverse, and continuous possession for over thirty years. They were unaware of any encumbrances or competing claims, and stated the land was not within a forest zone or government reservation. Procedural History: Marcos Camargo opposed the application, claiming ownership. The Government, through the Director of Forestry, also opposed, averring the land was part of the public domain, within an unclassified area, and thus not available for private appropriation. The Regional Trial Court (RTC) dismissed the application, holding that titles covering public domain classified as forest land are void and subject to cancellation. The RTC found no concrete evidence that the property was lawfully acquired by the applicants or their predecessors-in-interest, and noted the absence of a certification from the Bureau of Forestry that the land was no longer within an unclassified region. The Court of Appeals (CA) affirmed the RTC's decision, agreeing that the land was within the public domain and not available for private appropriation. The Petition: The Spouses Villarico filed a petition for review on certiorari with the Supreme Court, assailing the CA's decision for sustaining the trial court's findings on the lack of documentation, the death of Buenaventura Villarico, the alleged contrived tax declaration, and the absence of concrete evidence of lawful acquisition. They argued that the CA and RTC erred in dismissing their case.
Issue(s)
Whether the Court of Appeals erred in sustaining the trial court's findings on factual and evidentiary matters. Whether the subject parcel of land, despite alleged long-term possession, can be registered under the Torrens System if it forms part of the public domain classified as forest land.
Ruling
The petition is denied, and the decision of the Court of Appeals is affirmed in toto. The subject parcel of land is part of the public domain, specifically within an unclassified forest zone, and therefore incapable of private appropriation.
Ratio Decidendi
On the issue of factual and evidentiary matters: The Supreme Court reiterated that in a petition for review on certiorari under Rule 45 of the Rules of Court, only questions of law may be raised. The Supreme Court is not a trier of facts, and findings of fact by the trial court and the Court of Appeals are binding upon it. The Court found no compelling reason to reverse the findings of the lower courts regarding the lack of documentation, the status of Buenaventura Villarico's death, and the alleged contrived tax declaration, as these were matters of evidence. The Court emphasized that it does not inquire into factual and evidentiary matters in such appeals, citing Alicbusan v. Court of Appeals. On the registrability of land within the public domain: The Court affirmed the lower courts' ruling that the primordial issue is the character of the property. It held that the subject parcel of land was correctly adjudged to be within the unclassified forest zone and thus incapable of private appropriation. The Court reiterated the well-settled principle that forest lands cannot be owned by private persons, and possession thereof, no matter how long, does not ripen into a registrable title. The adverse possession that may be the basis for confirmation of an imperfect title refers only to alienable or disposable portions of the public domain. The applicants failed to present evidence that the land had been declassified by the Director of Forestry as disposable or alienable, or that it was acquired through lawful means for the acquisition of public lands. The Court cited Palomo v. Court of Appeals in support of the principle that forest lands cannot be privately owned.
Main Doctrine
Possession of forest lands, however long, does not ripen into a registrable title as forest lands cannot be owned by private persons and are incapable of private appropriation. Adverse possession can only be the basis for a grant of title or confirmation of an imperfect title over alienable or disposable portions of the public domain.