Republic of the Philippines (represented by Opol National Secondary Technical School), petitioner, vs. Nicanor Doldol, respondent.
FACTS
In 1959, respondent Nicanor Doldol occupied a portion of land in Barrio Pontacan, Opol, Misamis Oriental. He filed an application for saltwork purposes for the area with the Bureau of Forest Development on October 23, 1963, but the Director of Forestry rejected it on April 1, 1968. In 1965, the Provincial Board of Misamis Oriental passed a resolution reserving Lot 4932, Cad-237, Opol Cadastre as a school site, which reservation included the area occupied by Doldol. The Opol High School transferred to the site in 1970. On November 2, 1987, President Corazon Aquino issued Proclamation No. 180 reserving the area, including the disputed portion, for the Opol High School, renamed Opol National Secondary Technical School. The school demanded that Doldol vacate the portion for its projects, but he refused. Consequently, the school filed a complaint for accion possessoria with the Regional Trial Court (RTC) of Cagayan de Oro in 1991. The RTC ruled in favor of the school and ordered Doldol to vacate. On appeal, the Court of Appeals reversed the RTC decision, ruling that Doldol was entitled to the portion he occupied, having possessed it for thirty-two years from 1959 to 1991. The Court of Appeals denied the school’s motion for reconsideration, prompting the school to elevate the case to the Supreme Court.
ISSUE
Whether the Court of Appeals erred in applying Section 48(b) of Commonwealth Act No. 141 (the Public Land Act) as amended by Republic Act No. 1942 (requiring thirty years of possession) instead of the version amended by Presidential Decree No. 1073 (requiring possession since June 12, 1945), and consequently, whether respondent Nicanor Doldol acquired ownership or a better right of possession over the disputed land.
RULING
The Supreme Court ruled in favor of the petitioner, Republic of the Philippines (represented by Opol National Secondary Technical School). The Court held that the Court of Appeals erroneously applied an outdated version of Section 48(b) of the Public Land Act. The applicable law is Presidential Decree No. 1073, which amended Section 48(b) to require open, continuous, exclusive, and notorious possession and occupation of agricultural lands of the public domain under a bona fide claim of ownership since June 12, 1945, or earlier. The parties stipulated that Doldol’s occupation began only in 1959. Therefore, Doldol did not comply with the legal requirement for judicial confirmation of imperfect title. Not having acquired an imperfect title, Doldol could not assert a right superior to the school, especially since the land was reserved for the school by presidential proclamation. The Court reinstated the decision of the Regional Trial Court ordering Doldol to vacate the land.
