G.R. No. L-56077 February 28, 1985
REPUBLIC OF THE PHILIPPINES, petitioner, vs. COURT OF APPEALS, SPOUSES PRUDENCIO MAXINO and TARCIANA MORALES, et al., respondents.

FACTS

This case concerns the validity of the registration of 885 hectares of land in Mulanay, Quezon. In 1961, the Court of First Instance ordered the registration of the land, designated as Lot 1, in favor of the spouses Prudencio Maxino and Tarciana Morales, minus 200 hectares for other claimants. A decree and title were issued. Over eight years later, in 1969, the Republic filed a petition to annul the decision, decree, and title, contending the land was part of the unclassified public forest and that the Spanish possessory information title (an adjustment title) relied upon by the Maxinos covered only 29 hectares, not 885. The trial court denied the petition in 1970.
The order of denial was served on a special counsel of the Bureau of Forestry in November 1970, but a copy reached the Solicitor General’s Office only in September 1971. The Solicitor General appealed shortly thereafter. The Court of Appeals dismissed the appeal, ruling it was filed out of time because the reglementary period should be counted from the service of the order on the special counsel. The Republic elevated the case to the Supreme Court.

ISSUE

The primary issue is whether the Republic’s appeal from the trial court’s 1970 order was seasonably filed. The secondary issue is the merits of the annulment case regarding the land’s alienable status and the validity of the Spanish title.

RULING

The Supreme Court reversed the Court of Appeals and ruled the appeal was timely. The legal logic is that the thirty-day period to appeal should be reckoned from the time the Solicitor General’s Office was actually apprised of the order, not from the service on the special counsel or the fiscal. These representatives had no authority to decide on an appeal; such decision rested solely with the Solicitor General. The Court cited precedents (Republic vs. Polo, Republic vs. Mendoza) establishing that the State is not bound by service on the Solicitor General’s surrogates. Furthermore, in exceptional cases involving the public interest, such as the attempted registration of inalienable public forest land, the rules may be relaxed to serve the interest of justice, and the government should not be estopped by its agents’ errors.
On the merits, the Court annulled the registration. The land is incontestably within the public forest, certified as such by the Director of Forestry, and thus not alienable or disposable. The Spanish adjustment title from 1888, the basis of the Maxinos’ claim, explicitly covered only 29 hectares of pasture land. The monstrous discrepancy between 29 hectares and the 885 hectares (or 970 hectares per a later survey) actually registered cannot be justified by the rule that boundaries prevail over stated area. The Court found the title’s description of boundaries erroneous. Spanish titles are not indefeasible, and this one was void for covering non-registrable public forest land, akin to the ruling in Ramirez vs. Director of Lands. The trial court grievously erred in ordering registration. The application was dismissed.