GR 73085; (June, 1990) (Digest)
G.R. No. 73085 June 4, 1990
REPUBLIC OF THE PHILIPPINES, petitioner, vs. THE INTERMEDIATE APPELLATE COURT, PABLO, JUAN, JR., JULIAN, RUFINA, LEONOR, GLORIA TERESITA, ANTONIO, DOLORES, BERNARDO, JR., and MARIA VIOLETA, all surnamed MERCHAN, respondents.
FACTS
Private respondents, the Merchans, filed a complaint for quieting of title over a 166-hectare parcel of land in Lucban, Quezon, claiming ownership through a document they alleged to be a Spanish title issued to their predecessor, Bernardo Merchan. The Republic moved to dismiss, asserting the land was part of a forest reserve established by Proclamation No. 42 (1921) and later part of the Mts. Banahaw-San Cristobal National Park per Proclamation No. 716 (1941), placing it beyond the court’s jurisdiction. The trial court denied the motion. After procedural disputes, including a default order against the Republic that was later set aside, the trial court eventually rendered a decision in favor of the Merchans, declaring them co-owners. The Intermediate Appellate Court affirmed this decision.
ISSUE
Whether a parcel of land proclaimed as part of a forest reserve and later a national park can be subject to private appropriation and registration.
RULING
The Supreme Court reversed the appellate court’s decision and dismissed the case. The legal logic is anchored on the fundamental principle that forest lands or forest reserves, including those designated as national parks, are part of the inalienable public domain. Possession thereof, no matter how lengthy, cannot ripen into private ownership. The land in question was unequivocally classified as a forest reserve in 1921 and as a national park in 1941. As a public reservation, it is outside the commerce of man and cannot be disposed of or registered as private property. The Court cited a consistent line of jurisprudence establishing that such lands are not capable of private appropriation unless officially reclassified as alienable or disposable by the Director of Forestry, a condition absent in this case. Furthermore, the document presented by the Merchans was not a genuine Spanish title granting ownership but merely an instrument seeking recognition of possession. Finally, with the effectivity of Presidential Decree No. 892 in 1976, Spanish titles could no longer be used as evidence of land ownership in registration proceedings. Thus, the Merchans’ claim had no legal basis.