G.R. No. 48327 ; August 21, 1991
Republic of the Philippines, Director of Lands and Director of Forestry, petitioners, vs. Hon. Court of Appeals, Paulina Paran, Elisa Paran Maitim and Sina Paran, respondents.

FACTS

Private respondents Paulina Paran, et al., applied for judicial confirmation of their title over a 34,178-square-meter parcel of land in Benguet, claiming possession since time immemorial through their father. The Republic, through the Director of Lands and the Director of Forestry, opposed the application. The primary grounds were that the land was part of the public domain, specifically within the Central Cordillera Forest Reserve under Proclamation No. 217, and that the application was filed beyond the period provided by R.A. No. 2061 . The land registration court denied the motion to dismiss and, after trial, granted the application, confirming private respondents’ title. The Provincial Fiscal received the decision on August 13, 1974, but did not appeal. The Solicitor General, receiving a copy on August 26, 1974, filed a motion for reconsideration on September 25, 1974, which was denied. He then filed a notice of appeal on August 18, 1975. The Court of Appeals dismissed the Republic’s appeal, ruling it was filed out of time, as the period to appeal commenced from the Provincial Fiscal’s receipt of the decision, making the land registration court’s decision final and executory.

ISSUE

The primary issue is whether the Court of Appeals erred in dismissing the Republic’s appeal on the ground of finality of judgment, and secondarily, whether the land registration court had jurisdiction over the land classified as part of a forest reserve.

RULING

The Supreme Court reversed the Court of Appeals and addressed the substantive issues. On procedural grounds, the Court held that the period to appeal for the government should be reckoned from the Solicitor General’s receipt of the decision, as he is the principal counsel for the government under P.D. No. 478. Thus, the appeal was timely perfected. On the merits, the Court ruled that the land registration court had jurisdiction. The argument that the application was filed beyond the period in R.A. No. 2061 was untenable, as said period had been subsequently extended by R.A. No. 6236 . More importantly, the Court found that the land, although within the forest reserve, was no longer forestal but was already converted to agricultural use through private respondents’ long-term possession and cultivation, as evidenced by terraces and dikes. Applying the Public Land Act ( C.A. No. 141 ), the Court held that private respondents had acquired an imperfect title through open, continuous, exclusive, and notorious possession since June 12, 1945, or earlier, which is susceptible to judicial confirmation regardless of the land’s prior classification. Therefore, the decision of the land registration court was affirmed.