Central Mindanao University v. Republic
REITERATIONFacts
The Antecedents: Central Mindanao University (CMU) took possession of two parcels of land in Musuan, Maramag, Bukidnon in 1946 for its school site. These lands were officially reserved for CMU's purposes by President Carlos P. Garcia through Proclamation No. 476 in 1958, withdrawing them from sale or settlement but explicitly subject to private rights. Despite this reservation, CMU discovered adverse claimants and occupants on portions of the land during a survey. Procedural History: Following a directive from the Office of the President, the Director of Lands filed a petition in 1961 with the Court of First Instance (CFI) of Bukidnon for the compulsory registration of these reserved parcels. The CFI issued an initial decision in 1971, declaring the lands public but registrable to CMU, except for specified portions adjudicated to private claimants. This decision was amended in 1972 and further modified in 1974 through a second amended decision, which adjudicated specific portions to various claimants and other portions to CMU. Consequently, Decrees No. N-154065, N-154066, and N-154067 were issued in favor of CMU, leading to the registration of Original Certificates of Title (OCT) Nos. 0-160, 0-161, and 0-162 in its name on January 29, 1975. In 2003, the Republic of the Philippines, through the Solicitor General, filed a petition for annulment of these CFI decisions and the subsequent titles, arguing that the cadastral court lacked jurisdiction because the lands were inalienable public domain and the registration petition was not properly filed by the Solicitor General. The Court of Appeals granted this petition, declaring the CFI decisions and CMU's titles null and void. The Petition: CMU filed a petition for review on certiorari under Rule 45 of the Rules of Court, assailing the Court of Appeals' decision. CMU contends that the Court of Appeals committed a grave error in ruling that the cadastral court lacked jurisdiction. CMU argues that the directive from the President, through the Assistant Executive Secretary, authorizing the Director of Lands to file the compulsory registration petition was equivalent to a declaration that the subject lands were alienable and disposable, citing precedent. CMU maintains that the documents presented during the cadastral proceedings sufficiently showed that the property had been declared, classified, and certified as alienable and disposable by the Office of the President.
Issue(s)
Whether the Court of Appeals committed a serious and grave error and gravely abused its discretion in granting the petition for annulment of judgment on the ground that the cadastral court had no jurisdiction over the subject matter because the subject lands are inalienable and non-disposable lands of the public domain. Whether the directive from the President authorizing the Director of Lands to file a petition for compulsory registration is equivalent to a declaration that the subject lands are alienable and disposable.
Ruling
The petition is denied. The decision of the Court of Appeals is affirmed. The proceedings in the Court of First Instance are declared NULL and VOID. Original Certificate of Title Nos. 0-160, OCT No. 0-161 and OCT No. 0-162 issued in the name of petitioner are CANCELLED. Sheet 1, Lot 1 of Ir-1031-D and Sheet 2, Lot 2 of Ir-1031-D are ORDERED REVERTED to the public domain.
Ratio Decidendi
On the issue of whether the cadastral court had jurisdiction and if the lands are alienable and disposable: The Supreme Court affirmed the CA's ruling that the cadastral court lacked jurisdiction. The Court reiterated the Regalian Doctrine, stating that all lands of the public domain belong to the State and that the burden of proof to overcome this presumption lies with the applicant. To prove that land is alienable, there must be a positive act from the government, such as a presidential proclamation, executive order, administrative action, investigation reports, or a legislative act. Proclamation No. 476, which reserved the lands for CMU's site purposes, explicitly withdrew them from sale and settlement and declared them non-alienable and not subject to disposition under Section 88 of C.A. No. 141, unless again declared alienable by proclamation or act of the President. The Court found no such positive act reclassifying the reserved lands as alienable and disposable. The Supreme Court reiterated that the burden of proof to overcome the presumption of State ownership of public domain lands rests on the applicant. This requires incontrovertible evidence of a positive act by the government declaring the land alienable and disposable. Given that the lands were inalienable public domain, the cadastral court exceeded its jurisdiction in adjudicating them to CMU. Consequently, the decrees and titles issued in CMU's name were void ab initio. The CA correctly annulled these titles and ordered the reversion of the lands to the public domain. The Court dismissed CMU's other arguments regarding the Solicitor General's consent and the alleged singling out of its titles for lack of evidence and because they were not discussed by the CA. On whether the presidential directive is equivalent to a declaration of alienability: The Court distinguished the present case from Republic v. Judge De la Rosa. In De la Rosa, the directive was issued when the land was not reserved for public or quasi-public purposes and had reverted to public agricultural land. In contrast, the subject lots in the present case were reserved for educational purposes under Proclamation No. 476 and had not ceased to be so at the time the directive was made. Therefore, the directive authorizing the filing of a compulsory registration petition for lands still under reservation for public purpose cannot be considered an equivalent declaration of alienability and disposability. The Court emphasized that for such a directive to be considered equivalent to a declaration of alienability, the land should not have been reserved for public or quasi-public purposes, as per Section 8 of C.A. No. 141. The Court cited its previous rulings in CMU v. DARAB and CMU v. Executive Secretary, which held that the CMU land reservation is not alienable and disposable land of the public domain. These prior decisions established that the lands, by their character, became inalienable from the moment they were dedicated for CMU's use for scientific and technological research in agriculture. The Court clarified that its pronouncement in CMU v. DARAB that the land was private land registered in CMU's name was merely to explain why it was exempt from CARP coverage and did not signify that the land was alienable or disposable. CMU failed to present such evidence beyond the indorsements and the presidential directive, which, as established, did not constitute a declaration of alienability in this context. Therefore, the land reservations remained part of the inalienable public domain and were not registrable under the Torrens system.
Main Doctrine
A presidential directive authorizing the Director of Lands to file a petition for compulsory registration of reserved lands does not automatically convert such lands into alienable and disposable, especially when the reservation for public or quasi-public purpose has not ceased. The burden of proof to establish that land is alienable and disposable rests on the applicant, requiring a positive act from the government.