G.R. No. 75672 & 75673. April 19, 1989.
HEIRS OF GUMANGAN, et al. vs. COURT OF APPEALS, DIRECTOR OF LANDS, and DIRECTOR OF FOREST DEVELOPMENT. / HEIRS OF MOLINTAS, et al. vs. COURT OF APPEALS, DIRECTOR OF LANDS, DIRECTOR OF FOREST DEVELOPMENT, et al.

FACTS

The Heirs of Gumangan and the Heirs of Molintas filed separate applications for original land registration covering parcels of land in Baguio City. The Director of Lands moved to dismiss both applications, arguing the trial court lacked jurisdiction because the lands were part of the public domain, their disposition being vested in the Director of Lands under the Public Land Act. He further contended the claims were barred by the Statute of Limitations and by a prior 1922 judgment in Civil Reservation Case No. 1, which declared certain lands in Baguio as public. The trial court granted the motions to dismiss. Petitioners moved for reconsideration, asserting their lands were within the Busol Forest Reservation, which was expressly excluded from the 1922 reservation proceedings, and thus their claims were not barred by res judicata. The trial court denied reconsideration.
On appeal, the Court of Appeals dismissed the petitions. It found that the lands applied for were indeed within the Busol Forest Reservation, established in 1922. Petitioners argued that their predecessors had the lands surveyed even before the reservation’s creation and that the 1922 decision itself excluded the Busol Forest from its declaration of public lands. However, the appellate court held that regardless of any prior survey or exclusion from the 1922 case, the decisive fact was the land’s classification as part of a forest reservation.

ISSUE

Whether a parcel of land within a forest reservation can be titled through original land registration proceedings.

RULING

No. The Supreme Court affirmed the dismissal of the petitions. The legal logic is anchored on the fundamental principle of inalienability of forest lands. Lands classified as forest or timber lands are part of the inalienable public domain. Possession thereof, no matter how lengthy, cannot ripen into private ownership or convert the land into alienable or disposable property. The Court cited established jurisprudence, including Director of Lands vs. Abanzado and Vano vs. Government of the Philippine Islands, which uniformly hold that forest lands cannot be acquired by prescription or private claim. Since the subject parcels are admittedly within the Busol Forest Reservation, they are, by legal definition, forest lands. Consequently, the courts have no jurisdiction to adjudicate such lands in registration proceedings. The argument that the lands were excluded from the 1922 reservation case is immaterial; the operative fact is their status as forest land, which places them beyond the reach of registration under the Land Registration Act. The proper recourse for claimants is to seek a reclassification of the land from the executive department, not judicial confirmation of title. The petitions were dismissed for lack of merit.