GR 129401; (February, 2001) (Digest)
G.R. No. 129401 February 2, 2001
FELIPE SEVILLE, et al., petitioners, vs. NATIONAL DEVELOPMENT COMPANY, et al., respondents.
FACTS
The petitioners, successors-in-interest to the estate of Joaquin Ortega, filed a complaint for recovery of real property against several respondents, including the National Development Company (NDC) and the Leyte Sab-A Basin Development Authority (LSBDA). They claimed ownership over a 735,333-square-meter parcel of land in Isabel, Leyte, alleging their predecessor had possessed it since 1912. The respondents derived their claim from a deed of sale executed by Calixtra Yap in favor of LSBDA in 1980. LSBDA subsequently obtained a Miscellaneous Sales Patent and an Original Certificate of Title, which it later assigned to NDC.
The Regional Trial Court ruled in favor of the petitioners, declaring the deed of sale void, recognizing the estate as the owner, and ordering the respondents to pay rentals and damages. The respondents appealed this decision to the Court of Appeals.
ISSUE
The core issue is whether the petitioners have established a valid and superior title to the subject land, thereby entitling them to recover it from the respondents who hold a certificate of title derived from a state grant.
RULING
The Supreme Court denied the petition and affirmed the Court of Appeals’ decision dismissing the complaint. The Court anchored its ruling on the Regalian doctrine. It emphasized that all lands of the public domain belong to the State, and unless a public land is shown to have been reclassified as alienable and disposable or actually alienated by the State to a private person, it remains part of the inalienable public domain.
The petitioners failed to present conclusive evidence that the land had been classified as alienable or that the State had granted it to Joaquin Ortega or his predecessors. Their claim of possession since 1912, even if proven, could not ripen into private ownership because prescription does not run against lands of the public domain. Occupation of forest land or other unclassified public land, regardless of length, cannot confer title. Since the property was untitled prior to LSBDA’s Miscellaneous Sales Patent, it was presumptively public land. The State, through the Bureau of Lands, validly granted title to LSBDA via the sales patent, which enjoys a presumption of regularity. The petitioners’ action, being essentially a collateral attack on a certificate of title, is impermissible. Their claim of ownership, unsupported by any state grant or proof of alienability, must fail.