G.R. No. 247866, September 15, 2020
FEDERATION OF CORON, BUSUANGA, PALAWAN FARMER’S ASSOCIATION, INC., ET AL. VS. THE SECRETARY OF THE DENR AND THE DAR

FACTS

Petitioners, representing farmer associations and occupants in Coron, Busuanga, Palawan, filed a Petition for Certiorari. They challenged the constitutionality of Section 3(a) of Presidential Decree No. 705 (the Forestry Reform Code), which classifies lands with a slope of 18% or more as part of the public forest domain. They argued this automatic classification, without considering actual use or occupancy, effectively renders millions of Filipino settlers and farmers on such lands as squatters, violating their constitutional rights.
The petitioners contended that this provision infringes upon their right to due process and the preferential right of qualified Filipinos to the use and enjoyment of natural resources. They sought a declaration that the law is unconstitutional and requested the respondents to undertake a proper classification of the lands they occupy to determine if these are alienable and disposable agricultural lands subject to agrarian reform.

ISSUE

Whether Section 3(a) of P.D. No. 705 is unconstitutional for allegedly violating the due process rights of occupants and for contravening the state policy on agrarian reform and the preferential use of natural resources by Filipino citizens.

RULING

The Court dismissed the petition and affirmed the constitutionality of Section 3(a) of P.D. No. 705. The legal logic is anchored on the Regalian Doctrine, a fundamental principle embedded in the Philippine constitutional and property regime. This doctrine, with origins in the Spanish Laws of the Indies and affirmed under successive constitutions, establishes that all lands of the public domain belong to the State. The State has the exclusive prerogative to classify lands as alienable and disposable or to retain them as part of the inalienable public forest.
The statutory classification based on slope gradient is a valid exercise of the State’s police power and its power of dominium. Its objective is a legitimate state interest: the conservation and protection of forest lands, which are critical for ecological balance, watersheds, and disaster prevention. The law creates a conclusive presumption that steep lands are forest lands, a legislative policy determination to prevent their exploitation and ensure sustainable management. This presumption does not violate due process. The proper remedy for occupants is not a judicial challenge to the classification standard itself, but to avail of administrative processes to prove that specific parcels have been officially reclassified or released by the State as alienable. The law’s constitutionality is upheld as a reasonable exercise of state authority over natural resources.