G.R. No. 195026 February 22, 2016
CENTRAL MINDANAO UNIVERSITY, represented by its President, DR. MARIA LUISA R. SOLIVEN, Petitioner, vs. REPUBLIC OF THE PHILIPPINES, represented by the Department of Environment and Natural Resources, Respondent.

FACTS

Petitioner Central Mindanao University (CMU) is a state-owned agricultural institution. In 1946, it took possession of two large parcels of land in Musuan, Bukidnon, for its school site. In 1958, President Carlos P. Garcia issued Proclamation No. 476, reserving these lands from sale or settlement for CMU’s use, “subject to private rights, if any.” Subsequently, the Director of Lands, authorized by the Office of the President, filed a petition for compulsory registration under the Public Land Act to settle the titles and adjudicate the claims of numerous occupants on the reserved land.
The cadastral court rendered decisions from 1971 to 1974, declaring the lands as public land included in CMU’s reservation and ordering their registration in CMU’s name, except for specific portions adjudicated to several private claimants. The court also recommended that other occupants be given the opportunity to acquire ownership. Decrees and Original Certificates of Title were subsequently issued in favor of CMU in 1975. Decades later, the Republic, through the DENR, filed a petition with the Court of Appeals to annul these titles.

ISSUE

Whether the cadastral court acquired jurisdiction over the compulsory registration proceedings, thereby rendering its decisions and the resulting titles in favor of CMU valid.

RULING

No, the cadastral court did not acquire jurisdiction. The Supreme Court affirmed the Court of Appeals’ decision annulling the titles. The legal logic is anchored on the mandatory requirement for the Solicitor General to initiate compulsory registration proceedings under Section 53 of the Public Land Act ( Commonwealth Act No. 141 ). The Court emphasized that the authority to file such a petition is vested solely in the Solicitor General, not the Director of Lands. The records showed that the petition was filed by the Director of Lands, and while there was an authorization from the Office of the President, there was no showing that the Solicitor General was requested by the Secretary of Agriculture and Natural Resources to file the petition, as required by the law’s procedure. Jurisdiction over the subject matter is conferred by law and cannot be conferred by the parties’ acquiescence. Since the petition was filed by an unauthorized party, the cadastral court never acquired jurisdiction over the case. Consequently, all proceedings, including the decisions and the decrees and titles issued pursuant thereto, are void. The land remains part of the public domain, reserved for CMU by proclamation, but the proper procedure for judicial confirmation of imperfect title must be followed.