G.R. No. 36343 , May 4, 1989
Republic of the Philippines, petitioner, vs. Hon. Julian B. De La Rosa, in his capacity as “Cadastral Judge” of the Court of First Instance of Isabela, Branch IV, and Jose Fajardo, respondents.

FACTS

The case involves Lot No. 7805 within the Mallig Plains Reservation in Isabela. The land was originally reserved for settlement under Proclamation No. 610 (1940) and administered successively by the National Land Settlement Administration (NLSA), the Land Settlement and Development Corporation (LASEDECO), and later considered for transfer to the National Resettlement and Rehabilitation Administration (NARRA). NARRA, however, did not include this reservation among the properties it needed. Subsequently, Proclamation No. 337 (1956) amended the original reservation by excluding areas already certified as alienable and disposable but not yet disposed of, and returned authority over such areas to the Director of Lands.
In 1951, the Director of Lands filed a cadastral petition for the Gamu Public Lands Subdivision, which included the subject lot. After publication and notice, the court issued an order of general default. Private respondent Jose Fajardo filed his answer during an extended period granted by the court, claiming ownership through continuous, open, and notorious possession since 1937. The Board of Liquidators, representing the government’s interest from the defunct LASEDECO, attempted to file an adverse claim in 1972, but it was denied for being filed out of time. The cadastral court adjudicated the lot in favor of Fajardo.

ISSUE

The primary issue is whether the cadastral court correctly adjudicated Lot No. 7805 in favor of Jose Fajardo, thereby confirming his imperfect title, despite the land’s history within a government reservation and the belated claim by the Board of Liquidators.

RULING

The Supreme Court affirmed the cadastral court’s decision. The legal logic rests on the conclusive reversion of the land to the public domain and Fajardo’s compliance with the requirements for judicial confirmation of imperfect title. Proclamation No. 337 effectively excluded the alienable and disposable portions of the Mallig Plains Reservation from the settlement reservation and restored the Director of Lands’ authority to administer them. Since NARRA did not adopt the reservation, the land automatically reverted to the status of public agricultural land disposable under the Public Land Act.
Fajardo established his claim under Section 48(b) of the Public Land Act, proving possession since 1937—well over the required 30-year period preceding the 1956 cadastral filing. The government, through the Board of Liquidators, failed to timely assert any adverse claim. Its 1972 answer was correctly rejected as a belated attempt to participate after the order of default and years of proceedings. The land, being alienable and disposable and not reserved for public use, was legally open to disposition. Fajardo, as a qualified claimant with proven possession, thus acquired a vested right to the grant, which the cadastral court properly recognized. The Court emphasized the Director of Lands’ primary control over the disposition of public lands and found no error in the confirmation of title.