GR 50260; (July, 1992) (Digest)
G.R. No. L-50260 July 29, 1992
DIRECTOR OF LANDS and DIRECTOR OF FOREST DEVELOPMENT, petitioners, vs. HON. COURT OF APPEALS and TRINIDAD S. DE ARMEDILLA, in substitution of MARIA CALANOG, respondents.
FACTS
Maria Calanog filed an application for judicial confirmation of title over a 598.4894-hectare tract of land in Masbate. The land was allegedly possessed as pasture land by Estanislao Patricio since 1914, sold to Vicente Montenegro in 1928, and then sold to Calanog in 1938. The Director of Lands and the Director of Forestry opposed the application, the latter alleging that 256 hectares of the land were within a certified timberland block. After Calanog’s death, Trinidad S. de Armedilla was substituted as applicant. The trial court granted the application, excluding only two lots already titled in another’s name. The Court of Appeals affirmed this decision. The petitioners (Directors of Lands and Forest Development) sought review, arguing that a significant portion is forest land where possession cannot ripen into ownership, that the area claimed vastly exceeded the area described in the original deed of sale, and that the required period of possession was not met.
ISSUE
Whether the Court of Appeals erred in affirming the grant of the application for judicial confirmation of title over the land.
RULING
Yes, the Court of Appeals’ decision is reversed and the application is denied. The Supreme Court found that the applicant failed to establish a registerable title. First, 256 hectares were conclusively shown by documentary evidence to be part of a timberland block, and forest lands are not subject to private appropriation; their classification is an executive, not judicial, prerogative. Second, there was a glaring, unexplained disparity between the 200-hectare area in the 1928 deed of sale and the 598 hectares applied for, which the applicant failed to satisfactorily prove. Third, the required period of possession was not met. The applicable law at the time required possession since July 26, 1894, but the applicant’s predecessors-in-interest only commenced possession in 1914. Furthermore, the possession was not continuous and exclusive, as the land was later occupied by numerous homestead applicants and patent grantees. Therefore, the applicant did not acquire an imperfect title susceptible to judicial confirmation.