G.R. No. 156951 & G.R. No. 173408, September 22, 2006
Republic of the Philippines, et al. vs. Southside Homeowners Association, Inc., et al. / Saguisag, et al. vs. Esperon, Jr.

FACTS

The Republic of the Philippines filed a complaint for declaration of nullity and cancellation of Transfer Certificate of Title (TCT) No. 15084 issued in the name of respondent Southside Homeowners Association, Inc. (SHAI). The title covers approximately 39.99 hectares within the Fort Andres Bonifacio Military Reservation (FBMR), a parcel of public domain reserved for military purposes by Presidential Proclamation No. 423 in 1957. SHAI acquired the title in 1991 via a deed of sale executed by a Director of the Lands Management Bureau. The Republic, joined by intervenors Bases Conversion Development Authority (BCDA), Department of National Defense (DND), and Armed Forces of the Philippines (AFP), argued the land remains inalienable public land. The Regional Trial Court dismissed the complaint, a decision affirmed by the Court of Appeals. In a consolidated petition, retired military officers also sought to restrain the AFP Chief of Staff from evicting occupants pending final resolution of the ownership issue.

ISSUE

The core issue is whether TCT No. 15084 issued to SHAI is valid, considering the land is part of a military reservation proclaimed as inalienable public domain.

RULING

The Supreme Court granted the petition and declared TCT No. 15084 null and void. The legal logic is anchored on the fundamental doctrine that lands of the public domain classified as forest, mineral, or national parks, including military reservations, are inalienable and cannot be disposed of unless they are first reclassified as alienable or disposable by positive act of the Executive Department. Proclamation No. 423 unequivocally withdrew the FBMR from sale or settlement, reserving it for military purposes. No subsequent proclamation reclassified the specific JUSMAG area as alienable. Therefore, the land remains non-disposable public land. The Director of Lands had no authority to execute a deed of sale covering inalienable land. Consequently, the title issued to SHAI, which originated from a void transaction, is itself void. The Court emphasized that a certificate of title cannot vest ownership where none exists, as the State cannot be bound by the unauthorized acts of its officers. The ancillary petition regarding eviction was rendered moot by this ruling on the nullity of SHAI’s title.