G.R. No. 247866 , September 15, 2020
FEDERATION OF CORON, BUSUANGA, PALAWAN FARMER’S ASSOCIATION, INC., ET AL. VS. THE SECRETARY OF THE DEPARTMENT OF ENVIRONMENT AND NATURAL RESOURCES (DENR) AND THE DEPARTMENT OF AGRARIAN REFORM (DAR)

FACTS

Petitioners are farmer associations and an individual representing farmers in Coron and Busuanga, Palawan. Their farmlands were initially placed under the coverage of the Comprehensive Agrarian Reform Program (CARP) by the DAR. However, the implementation was subsequently stopped after the DENR classified the subject lands as unclassified forest land under Section 3(a) of Presidential Decree No. 705 (The Forestry Reform Code). This classification rendered the lands inalienable and not subject to CARP distribution. The farmers, who had occupied and tilled these lands for decades, were formally informed that the CARP coverage could not proceed due to this forest land classification.
Petitioners argue that Section 3(a) of P.D. No. 705, which deems unclassified lands as forest lands, is unconstitutional. They contend it violates constitutional provisions across different charters, retroactively converts unclassified lands into forest lands, and deprives millions of Filipino occupants of any vested right to ownership. They assert that, following the Philippine Bill of 1902, unclassified lands not covered by trees should be considered agricultural, alienable, and disposable.

ISSUE

Whether Section 3(a) of Presidential Decree No. 705 is unconstitutional.

RULING

The Supreme Court DISMISSED the petition and upheld the constitutionality of Section 3(a) of P.D. No. 705. The legal logic is anchored on the Regalian Doctrine and the State’s plenary power to classify lands of the public domain. All lands of the public domain belong to the State, and no private rights can be acquired unless and until the State positively declares such lands as alienable and disposable. The Court emphasized that the classification of public lands is an exclusive prerogative of the Executive Department, pursuant to Section 6 of Commonwealth Act No. 141 (Public Land Act).
The Court ruled that Section 3(a) of P.D. No. 705 is a valid exercise of this classificatory power. It establishes a default status for unclassified lands as forest lands, which are inalienable. This is consistent with the constitutional policy of conservation and protection of forest resources. Petitioners failed to overcome the presumption of constitutionality accorded to the law. Their occupancy, no matter how long, did not create a vested right because the land was never declared alienable. The law does not violate any constitutional right, as petitioners had no property right to be violated over inalienable public forest land. The Court also found that the provision does not contravene the Philippine Bill of 1902 or subsequent constitutions, as the State’s authority to classify lands remains paramount.