G.R. Nos. L-46068-69, L-46247-48, L-46648 & L-47353. September 30, 1982.
THE DIRECTOR OF LANDS, EMILIO J. GUINOO, and MUNICIPALITY OF BANSALAN, DAVAO DEL SUR, petitioners, vs. HONORABLE COURT OF APPEALS and SALVADOR ZARTIGA (substituted by his heirs), respondents.

FACTS

Salvador Zartiga filed a complaint for recovery of possession and damages, claiming absolute ownership since time immemorial over nine lots encompassing approximately 290 hectares, which constituted the townsite of Bansalan, Davao del Sur. The area was already developed, inhabited by about 10,000 people, and contained numerous government and private structures. The Director of Lands intervened, asserting the lots were public agricultural land, and initiated compulsory registration proceedings. The Municipality of Bansalan also opposed, claiming the area as a townsite reservation.
Zartiga anchored his claim on a 1927 deed of sale from Datu Julian Bagobo. However, evidence showed the tax declaration for the datu was issued only on February 11, 1927, the very same date of the alleged sale to Zartiga. The boundaries of the claimed property were inconsistently described, and Zartiga took no action during the extensive development of the Bansalan townsite over the years.

ISSUE

Whether Salvador Zartiga acquired valid ownership over the nine lots, thereby removing them from the public domain.

RULING

No. The Supreme Court reversed the Court of Appeals and declared the lots, except two already titled to other individuals, as public land. Zartiga failed to prove a valid title. The Court found the purported 1927 sale from Datu Julian Bagobo highly suspect and ineffective. The simultaneous issuance of the tax declaration and the execution of the sale on the same day indicated a scheme to fabricate evidence of ownership for the datu to enable a quick transfer to Zartiga. This maneuver could not vest title, as the datu himself had no demonstrable right to alienate the land.
Furthermore, even assuming the sale occurred, it was expressly void under Section 84 of Commonwealth Act No. 141 (Public Land Act). This provision declares illegal and of no effect any conveyance of land executed by a datu or similar non-Christian chief without the requisite government authority or consent, whether during the Spanish or American regime. Since the sale lacked such authority, it conferred no rights upon Zartiga. Consequently, his action for recovery of possession had no legal basis, and the lands remained part of the public domain, subject to disposition under the Public Land Law.