Pagkatipunan v. Court of Appeals
REITERATIONFacts
The Antecedents: Petitioners' predecessors-in-interest applied for judicial confirmation and registration of title over certain lots in San Narciso, Quezon. An order of default was issued, and after a parcel was removed from the application, the Court of First Instance confirmed petitioners' title and issued an Original Certificate of Title (OCT) No. O-12665. Procedural History: Almost eighteen years later, the Republic of the Philippines filed an action to nullify the proceedings and the OCT, claiming the land was timberland and thus inalienable. The Intermediate Appellate Court (IAC) declared the land forestral and not registrable, nullifying the decision of the Court of First Instance and ordering the reversion of the land to the State. Petitioners' motion for reconsideration was denied, and the decision became final. Subsequent attempts by petitioners to set aside the entry of judgment were also denied. The Petition: Petitioners sought review of the Court of Appeals' decision, arguing their title became incontrovertible and indefeasible, and that the Republic's action was barred by prescription and res judicata. They contended the land was agricultural and its classification as timberland did not impair their vested rights.
Issue(s)
Whether the Republic's action to declare the proceedings and title void is barred by prescription and res judicata. Whether the land in question was alienable and disposable at the time of the application for registration. Whether the Court of First Instance acquired jurisdiction over the land registration case.
Ruling
The petition is denied. The decision of the Court of Appeals is affirmed in toto, declaring the Original Certificate of Title No. O-12665 and all derivative titles null and void, and ordering the reversion of the parcels of land to the State.
Ratio Decidendi
On whether the Republic's action is barred by prescription and res judicata: The Court held that prescription does not run against the State. Since the land remained part of the inalienable public domain, the lengthy occupation by petitioners could not be counted in their favor. The principle that all lands not appearing to be clearly within private ownership are presumed to belong to the State is paramount. The Republic's action to revert the land to the public domain was therefore not barred by prescription or res judicata. On whether the land was alienable and disposable: The Court found that evidence on record showed the land was classified as timberland at the time of the application for registration and issuance of the title. A certification from the Bureau of Forest Development confirmed this classification. Petitioners admitted the land was classified as forest land. Under the Regalian doctrine, all lands of the public domain belong to the State, and to overcome this presumption, incontrovertible evidence of alienability is required. The classification as timberland meant it was not subject to disposition under the Public Land Law. On whether the Court of First Instance acquired jurisdiction: Because the land was classified as timberland and thus unregistrable, the land registration court did not acquire jurisdiction over the res. Consequently, any proceedings had or judgment rendered therein were void and not entitled to the respect accorded to a valid judgment. The Court of Appeals correctly nullified the decision of the Court of First Instance for lack of jurisdiction.
Main Doctrine
Lands classified as timberland or forest land are part of the inalienable public domain and cannot be registered under the Torrens system unless there is a positive act from the government reclassifying them as alienable and disposable. Occupation, no matter how long, cannot ripen into ownership over such lands.