G.R. No. 129682 . March 21, 2002.
NESTOR PAGKATIPUNAN and ROSALINA MAÑAGAS-PAGKATIPUNAN, petitioners, vs. THE COURT OF APPEALS and REPUBLIC OF THE PHILIPPINES, respondents.

FACTS

In 1960, petitioners’ predecessors-in-interest applied for judicial confirmation of title over several lots in San Narciso, Quezon. The Court of First Instance granted the application in 1967, and an Original Certificate of Title was issued. Nearly eighteen years later, in 1985, the Republic filed an action to annul the registration proceedings and cancel the title. The Republic alleged that the land was classified as timberland, and thus inalienable, at the time of the application and the 1967 decision. It argued the registration court lacked jurisdiction over the res, rendering its judgment void.
Petitioners raised the defenses of indefeasibility of title and res judicata, contending the judgment had long become final and conclusive. The Intermediate Appellate Court (IAC) ruled in favor of the Republic in 1986, declaring the 1967 decision null and void, ordering the cancellation of the title, and reverting the land to the public domain. Petitioners’ subsequent motions for reconsideration and to recall the entry of judgment were denied, leading to this petition for review.

ISSUE

Whether the Court of Appeals correctly affirmed the nullification of the land registration decree and the reversion of the property to the public domain.

RULING

Yes. The Supreme Court affirmed the Court of Appeals’ decision. The core legal principle is that jurisdiction over the subject matter in land registration cases is conferred by law and requires that the land is alienable and disposable public land. If the land is not so classified, the registration court acquires no jurisdiction, and any judgment rendered is void. The Republic presented a Bureau of Forestry map (BF Map No. LC-1180) proving the land was classified as timberland under LC Project No. 15-B at the time of the application and the 1967 decision. No evidence was presented to show an official reclassification to alienable or disposable land prior to these critical dates.
Consequently, the 1967 registration decree was issued without jurisdiction and is void ab initio. A void judgment can be assailed at any time; the defenses of prescription, laches, and res judicata do not apply. The title, being sourced from a void judgment, is also void and confers no valid ownership. The Court rejected petitioners’ claim of vested rights based on possession, as such possession cannot ripen into ownership over inalienable public land. The State’s action for reversion, being an imprescriptible suit to assert its dominion over public domain, was properly granted. The land correctly reverted to the public domain.