G.R. No. L-77148, June 30, 1987
HEIRS OF MARIANO LACSON, represented by MAYO LACSON, and CALAGNA-AN AGRO-INDUSTRIAL CORPORATION, petitioners, vs. HONORABLE AMELIA K. DEL ROSARIO IN HER CAPACITY AS PRESIDING JUDGE OF THE FORMER COURT OF FIRST INSTANCE OF ILOILO, THE HONORABLE COURT OF APPEALS and THE REPUBLIC OF THE PHILIPPINES, respondents.

FACTS

The land in question, Lot 1, Psu-99817, was originally registered under Original Certificate of Title (OCT) No. 0-4 in the name of Mariano R. Lacson pursuant to a 1940 judgment in Land Registration Case No. 567. It was later transferred to Calagna-an Agro-Industrial Corporation under TCT No. T-71508. In 1975, the Republic of the Philippines filed a complaint to nullify the 1940 decision and the resulting titles, seeking reversion of the land to the State. The Republic alleged the land was timberland, part of the inalienable public domain, and that the registration court thus lacked jurisdiction. It also noted a prior appeal by the Director of Lands had been rendered moot by the destruction of records during the war.
The trial court initially dismissed the Republic’s complaint but later reversed itself in a 1979 Order, declaring a 971.65-hectare timberland portion as state property, annulling the corresponding titles, and ordering the petitioners to vacate. The Court of Appeals affirmed this order. The petitioners then elevated the case to the Supreme Court, arguing the registration court had jurisdiction, the prior appeal barred the reversion suit, and the burden of reconstituting lost records lay with the State.

ISSUE

The core issue is whether the State’s reversion suit to annul a land registration decree and corresponding titles, on the ground that the land is inalienable timberland, is legally tenable.

RULING

The Supreme Court dismissed the petition and affirmed the lower courts’ decisions. The legal logic is anchored on the fundamental principle that land registration courts have no jurisdiction over inalienable lands of the public domain. Since the property was established as timberland, it was not susceptible to private appropriation or registration. Consequently, the 1940 judgment and the OCT issued pursuant to it were void ab initio for lack of jurisdiction over the subject matter. A void judgment can be assailed at any time.
The Court rejected the argument that a pending appeal in the original registration case barred the reversion suit. The issuance of the decree and title during the war rendered that appeal impractical, making a direct action for annulment and reversion the proper remedy. Furthermore, the petitioners, as the parties claiming ownership, bore the burden of reconstituting the lost registration records to substantiate their claim, not the State. Finally, the doctrine of res judicata did not apply because one of its essential elements—a final judgment rendered by a court with jurisdiction—was absent. The registration court’s lack of jurisdiction over the timberland meant its decision could never attain finality as a valid adjudication of title.