G.R. No. L-32941 July 31, 1973
REPUBLIC OF THE PHILIPPINES, petitioner, vs. HON. PIO R. MARCOS, in his capacity as Judge, Court of First Instance of Baguio, Branch I, ALSON CARANTES, BILL CARANTES and EDUARDO CARANTES, respondents.

FACTS

On November 12, 1966, private respondents, the Carantes heirs, filed a petition to re-open Civil Registration Case No. 1 of the Court of First Instance of Baguio, a 1922 proceeding that established the Baguio Townsite Reservation. They sought registration in their favor of four lots with a total area of 74,017 square meters. The Director of Lands opposed, reporting the area was inside Camp John Hay, a military reservation. Despite this, respondent Judge Pio R. Marcos issued a decision on November 9, 1968, ordering the registration of the land in favor of the Carantes heirs. Efforts by the Director of Lands and the City of Baguio to appeal were denied by the respondent Judge, who held the proper appellant should be Camp John Hay itself. The Solicitor-General, not initially informed, later entered an appearance and filed a motion to annul the decision for lack of jurisdiction, which was also denied.

ISSUE

Whether the respondent Judge had jurisdiction to re-open the civil registration case and order the registration of land situated within a military reservation.

RULING

The Supreme Court granted the petition, annulling the decision of the respondent Judge for having been issued without jurisdiction. The legal logic is twofold. First, the statutory basis for re-opening, Republic Act No. 931 as amended, applies only to cadastral proceedings. Civil Registration Case No. 1, which established a townsite reservation, was not a cadastral proceeding. Therefore, the law did not grant the court authority to re-open that specific case. Second, and decisively, the land in question is indisputably part of Camp John Hay, a duly established military reservation. Lands within military reservations are part of the public domain and are inalienable. The court has no jurisdiction to adjudicate title over inalienable public lands. The claim of private respondents of possession since the Spanish regime and the annotation on survey plans “subject to prior and existing private rights” cannot overcome this fundamental jurisdictional barrier. The state, as represented by the Republic, is not estopped by the mistakes or errors of its officials. The Court cited its prior decision in Republic v. Marcos (G.R. No. L-29675), which involved the same judge and a similar attempt to re-open a non-cadastral proceeding concerning land within a reservation, as controlling precedent. Consequently, the challenged decision was void from inception.