GR 193618; (November, 2016) (Digest)
G.R. No. 193618 . November 28, 2016
HEIRS OF LEOPOLDO DELFIN AND SOLEDAD DELFIN, NAMELY EMELITA D. FABRIGAR AND LEONILO C. DELFIN, PETITIONERS, VS. NATIONAL HOUSING AUTHORITY, RESPONDENT.
FACTS
The petitioners, heirs of spouses Leopoldo and Soledad Delfin, filed a complaint for payment and damages against the National Housing Authority (NHA). They claimed ownership of a parcel of land in Iligan City, which they allegedly purchased in 1951 from individuals who had possessed it since time immemorial. They asserted they had declared the land for taxation and cultivated it. They alleged that in 1982, the NHA forcibly took possession of a portion of the land for a slum improvement and resettlement program without paying just compensation. The Regional Trial Court (RTC) ruled in favor of the Delfin spouses, ordering the NHA to pay the value of the land and improvements, after declaring the NHA in default for failing to appear at pre-trial.
The NHA appealed, arguing the land was part of a military reservation and later proclaimed for public use under Proclamation No. 2143. The Court of Appeals (CA) reversed the RTC, dismissing the complaint. The CA ruled the property remained part of the inalienable public domain, as the petitioners failed to prove it was already classified as alienable and disposable land of the public domain before the NHA’s taking. The petitioners elevated the case to the Supreme Court via a Petition for Review on Certiorari.
ISSUE
Whether the petitioners have a valid claim for just compensation against the NHA, presupposing they had acquired a vested right of ownership over the subject land prior to its taking by the government.
RULING
The Supreme Court denied the petition and affirmed the CA decision. The core legal principle is that no private title can be acquired over public domain lands unless there is proof that the land has been classified as alienable and disposable, and that the claimant has possessed it openly, continuously, exclusively, and notoriously since June 12, 1945, or earlier. The Court clarified that acquisitive prescription under the Property Registration Decree (P.D. No. 1529) can only run against the State’s patrimonial property, not against lands of the public domain. For land of the public domain to become patrimonial, a positive act of the government, such as a law or presidential proclamation reclassifying it, is required.
In this case, the petitioners failed to present any certification from the proper government agency attesting that the land was classified as alienable and disposable prior to the filing of their complaint. The land was, in fact, subject to Proclamation No. 2143, which reserved it for public use—specifically for slum improvement and resettlement. Since the land was not shown to have been converted into patrimonial property of the State, the petitioners could not have acquired ownership through prescription. Consequently, they had no compensable interest when the NHA took possession. Their claim for just compensation, which presupposes ownership, therefore lacked merit. The taking was an act of the State over its own public domain land.