Collado v. Court of Appeals
REITERATIONFacts
The Antecedents: Petitioners filed an application for registration of title over a parcel of land (Lot Psu-162620) with an approximate area of 120.0766 hectares, alleging open, public, notorious, and owner-like possession since time immemorial. They claimed their possession and ownership traced back to Sesinando Leyva in 1902, with subsequent transfers and tax declarations. Procedural History: The Republic of the Philippines and the Municipality of Antipolo opposed the application. The land registration court initially issued orders of default against the world except the oppositors. Despite repeated failures of oppositors to present evidence, the land registration court eventually rendered a decision confirming petitioners' imperfect title, citing evidence of possession and payment of taxes, and stating that Presidential Proclamations are subject to private rights. The Petition: The Solicitor General filed a Petition for Annulment of Judgment with the Court of Appeals, arguing that the Lot was not shown to be alienable and disposable, being inside the Marikina Watershed Reservation. Subsequently, Bockasanjo ISF Awardees Association, Inc. (intervenors) also sought to intervene, asserting their rights as occupants under the Integrated Social Forestry Program and claiming the Lot is inalienable. The Court of Appeals granted the intervention and, in its decision, declared the Regional Trial Court's decision null and void, finding that the Lot is part of the Marikina Watershed Reservation and thus inalienable.
Issue(s)
Whether the Court of Appeals erred in reversing the trial court's decision granting the application for confirmation of title. Whether the Court of Appeals erred in giving due course to the Republic's petition for annulment of judgment filed after the trial court's decision allegedly became final. Whether the Court of Appeals erred in giving due course to the intervenors' petition for intervention filed after the trial court's decision allegedly became final.
Ruling
The petition is bereft of merit. The Decision of the Court of Appeals dated June 22, 1992, declaring null and void the Decision dated January 30, 1991, of the Regional Trial Court of Antipolo, Rizal, is affirmed.
Ratio Decidendi
On the first issue of whether petitioners have registrable title over the Lot: The Court affirmed the Court of Appeals' ruling that petitioners failed to acquire a valid and enforceable right or title. The Regalian Doctrine mandates that all lands of the public domain belong to the State, and private ownership can only be acquired through a grant from the State. Petitioners failed to present evidence that the Lot was declassified as part of the Marikina Watershed Reservation and declared alienable and disposable. Executive Order No. 33 established the Marikina Watershed Reservation, and subsequent proclamations (Proclamation Nos. 1283 and 1637) did not definitively remove the Lot from its watershed status or render it alienable for private appropriation. The Court emphasized that possession of forest lands or inalienable public lands cannot ripen into private ownership, and the period of occupancy after the issuance of EO 33 could not be counted for purposes of confirming imperfect title because the Lot was no longer susceptible of disposition. On the second issue of whether the petition for annulment of judgment should have been given due course: The Court held that the procedural infirmities in filing the petition for annulment of judgment are immaterial because the land registration court never acquired jurisdiction over the Lot. Since the Lot is established as part of the Marikina Watershed Reservation, it is not alienable and disposable public land, rendering any title void ab initio. Therefore, all proceedings of the land registration court involving the Lot were null and void. The Court applied the principle that the Land Registration Court has no jurisdiction over non-registrable properties, and the State is not bound by prescriptive periods when asserting its rights over public lands. Environmental consequences were deemed to override technicalities and procedural rules. On the third issue of whether the petition-in-intervention is proper: The Court found no error in the Court of Appeals allowing the intervention. While intervention is generally allowed before rendition of judgment, exceptions exist in the interest of substantial justice. The Court noted that the intervention provided a venue for rival groups to ventilate their sides, especially given the history of disputes and violence surrounding the area. The Court of Appeals did not pass upon the actual status of the intervenors or the validity of their stewardship contracts, as these were not the issues presented. The primary purpose was to allow the intervenors to assert their claim that the Lot remains inalienable public land.
Main Doctrine
Lands within a watershed reservation are inalienable and indisposable public land. Possession thereof, no matter how long, cannot ripen into private ownership, and courts are without jurisdiction to adjudicate lands within a forest zone. A positive act of government is needed to declassify public land and convert it into alienable or disposable land.