AM MTJ 02 1440; (February, 2006) (Digest)
March 16, 2026GR 161925; (November, 2009) (Digest)
March 16, 2026G.R. No. 105912 June 28, 1999
SPOUSES TEOFILO C. VILLARICO and MAXIMA A. FAUSTINO, petitioners, vs. HONORABLE COURT OF APPEALS, REPUBLIC OF THE PHILIPPINES and MARCOS CAMARGO, respondents.
FACTS
Petitioners Spouses Teofilo and Maxima Villarico filed an application for confirmation and registration of title over a 1,834-square-meter parcel of land in Meycauayan, Bulacan. They claimed ownership by purchase from Teofilo’s father and alleged that they and their predecessors-in-interest had been in open, continuous, exclusive, and notorious possession of the land for more than thirty (30) years. They asserted the land was not within any forest zone or government reservation.
The Republic of the Philippines, through the Director of Forestry (now Forest Management), opposed the application. The government presented evidence, specifically LC Map No. 637 dated March 1, 1927, classifying the area as part of the unclassified public forest domain of Meycauayan, Bulacan, and thus inalienable. Private respondent Marcos Camargo also opposed, claiming ownership.
ISSUE
Whether the land subject of the application for registration forms part of the alienable and disposable lands of the public domain.
RULING
The Supreme Court DENIED the petition and AFFIRMED the Court of Appeals’ decision dismissing the application for registration. The Court held that the core issue was the classification of the land. Both the trial court and the Court of Appeals found, based on the official LC Map presented by the government, that the land was within an unclassified forest zone. The petitioners failed to present a certification from the proper government agency, specifically the Bureau of Forestry, reclassifying the land as alienable and disposable. The Court reiterated the fundamental principle that forest lands, or lands classified as such, are part of the inalienable public domain. Possession thereof, no matter how lengthy, cannot ripen into private ownership or confer a registrable title. Only alienable or disposable portions of the public domain may be acquired through acquisitive prescription or confirmation of imperfect title. Since the petitioners failed to overcome the presumption that the land remained part of the inalienable public forest, their application was properly dismissed. The Court also declined to review the factual findings of the lower courts, as a petition for review under Rule 45 is limited to questions of law.