GR 36995; (April, 1934) (Digest)
G.R. No. 36995 ; April 19, 1934
ALFREDO RAMIREZ and PAZ BAYOT DE RAMIREZ, applicants-appellees, vs. THE DIRECTOR OF LANDS, ET AL., oppositors. THE DIRECTOR OF LANDS and THE DIRECTOR OF FORESTRY, appellants.
FACTS
The spouses Alfredo Ramirez and Paz Bayot, Filipino citizens, applied for registration of a 203-hectare parcel of land in Siniloan, Laguna. The Director of Lands, Director of Forestry, and the municipalities of Siniloan and Famy opposed, claiming the land was public forestry land granted as communal forests. The applicants traced their title to a 1896 Spanish-era adjustment title (Exhibit D-2) issued to Tomas Ilao, who sold the land in 1897. The land was subsequently sold several times until the applicants purchased a portion in 1929. The applicants presented evidence of possession and cultivation (e.g., planting coffee trees), while the oppositors presented evidence that the land was thickly forested and that homestead applications had been denied as it was forestry land.
ISSUE
Whether the applicants have a registrable title to the land under the applicable public land laws.
RULING
No. The Supreme Court reversed the trial court’s judgment granting registration. The land was forestry land, not agricultural land, and therefore inalienable and not subject to registration under Act No. 2874 . The applicants and their predecessors-in-interest failed to prove the required open, continuous, exclusive, and bona fide possession since 1888. The 1896 title (Exhibit D-2) was irregular and did not establish valid ownership. Mere tax declarations and occasional visits do not constitute acts of possession. Since the land was classified as forest, it remained part of the public domain. The application for registration was denied, and the land was declared forestry land.
AI Generated by Armztrong.