Federation of Coron, Busuanga, Palawan Farmer's Association v. Secretary of the Department of Environment and Natural Resources
REITERATIONFacts
The Antecedents: Petitioners, farmer's associations and an individual, sought to have lands in Palawan covered by the Comprehensive Agrarian Reform Program (CARP). These lands were titled under Mercury Group of Companies and Josefa Sandoval Vda. De Perez. However, the CARP implementation was stopped because the Department of Environment and Natural Resources (DENR) classified the lands as unclassified forest land under Section 3(a) of Presidential Decree (P.D.) No. 705, rendering them inalienable and belonging to the government, thus under DENR's administration, not the Department of Agrarian Reform (DAR). Procedural History: Petitioners were formally informed by DAR officials that CARP coverage would not proceed due to the forest land classification. This led to the filing of the present petition for certiorari seeking to declare Section 3(a) of P.D. No. 705 unconstitutional. The Petition: Petitioners argue that Section 3(a) of P.D. No. 705 violates various constitutional provisions and the Philippine Bill of 1902 by retroactively changing unclassified lands into forest lands, thereby depriving millions of Filipinos of vested rights of ownership. They contend that unclassified lands should be considered alienable and disposable, and only lands with trees should be classified as forest land.
Issue(s)
WHETHER SECTION 3(A) OF PRESIDENTIAL DECREE NO. 705 IS UNCONSTITUTIONAL. WHETHER PETITIONERS HAVE THE LEGAL STANDING (LOCUS STANDI) TO FILE THE PETITION.
Ruling
The petition is dismissed for lack of merit. Section 3(a) of P.D. No. 705 is declared constitutional. Petitioners failed to discharge the heavy burden of proving unconstitutionality and to establish their locus standi. The Court found no violation of private rights as the subject lands, being unclassified, remain State property.
Ratio Decidendi
On the constitutionality of Section 3(a) of P.D. No. 705: The Court reiterated the presumption of constitutionality afforded to every statute, placing the burden on the petitioners to prove a clear and unequivocal breach of the Constitution. Petitioners failed to discharge this burden. Section 3(a) of P.D. No. 705, which defines public forest as lands of the public domain not yet classified, is consistent with the Regalian Doctrine, a principle deeply embedded in Philippine constitutional law since the Philippine Bill of 1902 and reiterated in subsequent constitutions. This doctrine posits that all lands of the public domain belong to the State, and the State is the source of all asserted rights to ownership. Consequently, unclassified lands are presumed to be forest lands and part of the inalienable public domain, not subject to private ownership or disposition unless there is a positive act from the government to reclassify them as alienable and disposable. The argument that unclassified lands should be presumed agricultural is misplaced, as the power to classify lands of the public domain now rests exclusively with the Executive Branch, not the courts, since the enactment of Act No. 2874 in 1919. Therefore, Section 3(a) of P.D. No. 705 does not violate any constitutional provision; rather, it upholds the State's ownership over its patrimony. On the locus standi of the petitioners: The Court found that petitioners failed to prove they have the requisite legal standing to file the constitutional challenge. Locus standi requires a personal and substantial interest in the case, meaning the party has sustained or will sustain direct injury as a result of the governmental act being challenged. Petitioners' bare assertion of being recipients of CARP distribution was unsubstantiated by evidence of actual occupation, possession, or any attempt to secure a reclassification of the lands. They did not present proof of direct injury traceable to the DENR's classification or that a favorable ruling would redress their alleged injury. Without demonstrating a direct and material interest in the subject lands, they cannot be considered as having the necessary standing to question the constitutionality of the law.
Main Doctrine
Unclassified lands of the public domain are presumed to be forest lands and thus part of the inalienable State patrimony, consistent with the Regalian Doctrine. A positive act from the government is required to reclassify such lands as alienable and disposable. Petitioners failed to establish locus standi and overcome the presumption of constitutionality of Section 3(a) of P.D. No. 705.