G.R. No. 115747 & 116658; November 20, 2000
Republic of the Philippines, et al. vs. Court of Appeals, Maria Natividad Aliño, et al.; Benigno G. Olleres, et al. vs. Court of Appeals, Heirs of Natividad Aliño.

FACTS

Maria Natividad Aliño filed an application for confirmation and registration of title over five parcels of land in Mamburao, Occidental Mindoro, with an aggregate area of 377,216 square meters. She claimed ownership by inheritance from her father, asserting that she and her predecessor-in-interest had possessed the lands openly, continuously, adversely, and in the concept of an owner since time immemorial, even prior to 1890. The application was opposed by several parties, including Benigno Olleres, the heirs of Estanislao Temenia, and the Republic of the Philippines through the Director of Lands and the Bureau of Forest Development. The oppositors claimed actual possession of portions of the land, while the Republic asserted that the lands were part of the public domain, specifically classified as forest land or alienable and disposable land only in 1965.
The trial court dismissed the application. On appeal, the Court of Appeals reversed the trial court and granted the registration, finding that Aliño and her predecessors had established possession since 1913, which met the required period for acquisitive prescription. The Republic and the private oppositors then filed separate petitions for review with the Supreme Court.

ISSUE

The core issue is whether the respondents have sufficiently established a registrable title to the subject lands by proving open, continuous, exclusive, and notorious possession under a bona fide claim of ownership since June 12, 1945, or earlier, as required for confirmation of imperfect title.

RULING

The Supreme Court reversed the Court of Appeals and denied the application for registration. The legal logic hinges on the fundamental principle that forest lands are part of the inalienable public domain. Possession thereof, no matter how lengthy, cannot ripen into private ownership. The Court found that the earliest official classification showed the lands were forest land as of 1927. While the applicant claimed possession since 1913, this possession was legally ineffective to acquire title because the property was not yet alienable and disposable. The land was only declared alienable and disposable by the Director of Forestry on January 3, 1965. For acquisitive prescription to operate, the requisite possession must occur after the land has been declared alienable. Therefore, possession prior to 1965 could not be counted. The applicant failed to prove possession for the required period (30 years then, or since June 12, 1945) after the land’s reclassification. Consequently, the land remains public domain belonging to the State. The statute of limitations does not run against the State for public lands, and no vested right is acquired without a positive act of the government declaring land alienable.