G.R. No. 36343. May 4, 1989.
REPUBLIC OF THE PHILIPPINES, petitioner, vs. HON. JULIAN B. DE LA ROSA, in his capacity as “Cadastral Judge” of the Court of First Instance of Isabela, Branch IV, and JOSE FAJARDO, respondents.

FACTS

The case involves Lot No. 7805 within the Mallig Plains Reservation in Isabela, originally reserved for settlement by Proclamation No. 610. Administration of the reservation was successively held by the National Land Settlement Administration (NLSA), the Land Settlement and Development Corporation (LASEDECO), and later the National Resettlement and Rehabilitation Administration (NARRA). In 1956, President Magsaysay issued Proclamation No. 337, amending the original reservation by excluding areas already certified alienable and disposable but not yet disposed of or contested, and returning authority over such areas to the Director of Lands. NARRA had previously determined it did not need the Mallig Plains Reservation for its purposes.
In 1951, the Director of Lands filed a cadastral petition for the Gamu Public Lands Subdivision, which included Lot No. 7805. After publication and notice, the court issued an order of general default. Private respondent Jose Fajardo filed his answer during an extended period. The Board of Liquidators, representing the defunct LASEDECO, attempted to file an adverse claim over all lands in the case in 1972, but its answer was rejected as filed out of time. The cadastral court adjudicated Lot No. 7805 in favor of Fajardo based on his continuous, open, and notorious possession since 1937.

ISSUE

Whether the cadastral court erred in adjudicating Lot No. 7805 to Jose Fajardo, considering the land was part of a government reservation and the claim of the Board of Liquidators.

RULING

The Supreme Court affirmed the decision. The legal logic rests on the reversion of the land to the public domain and its availability for disposition under the Public Land Act. Proclamation No. 337 effectively excluded from the reservation those areas already certified alienable and disposable but not yet disposed of, returning administrative authority to the Director of Lands. Since NARRA did not include the Mallig Plains Reservation among the properties it needed, the land automatically reverted to being public agricultural land. Furthermore, the land was not reserved for public or quasi-public uses under the relevant statutes. Consequently, it fell under Section 48(b) of the Public Land Act, which allows judicial confirmation of imperfect title based on open, continuous, exclusive, and notorious possession since June 12, 1945, or earlier. The Court found Fajardo’s possession, which commenced in 1937, to be duly proven and qualified. The claim of the Board of Liquidators was correctly denied for being filed out of time and without merit, as its authority over the land had ceased with the issuance of Proclamation No. 337 and the reversion of the land to the Director of Lands for disposition.