G.R. No. 85322; April 30, 1991
ALFREDO M. ALMEDA, LEONARDO M. ALMEDA and ERNESTO M. ALMEDA, petitioners, vs. HON. COURT OF APPEALS and REPUBLIC OF THE PHILIPPINES, represented by THE DIRECTOR OF LANDS, respondents.

FACTS

Petitioners Alfredo, Leonardo, and Ernesto Almeda applied for the registration of a 1,208-square-meter parcel of land in Pateros, Rizal. They claimed ownership through inheritance from their father, Emiliano Almeda, who allegedly inherited it from his parents. They asserted that their family’s possession, together with their predecessors-in-interest, had been public, peaceful, continuous, adverse, and in the concept of an owner for over thirty years. The Regional Trial Court granted their application, confirming their title and ordering its registration.
The Republic, through the Director of Lands, appealed to the Court of Appeals. The oppositor argued that the land was classified as forest land until it was declared alienable and disposable only on January 23, 1968, under Project No. 29. Consequently, the petitioners’ possession prior to that date could not be counted toward the required period of possession under the Public Land Act. The Court of Appeals reversed the trial court, ruling that the petitioners’ possession could only be counted from January 23, 1968, the date of the land’s reclassification, until the filing of their application on September 12, 1984—a period of only seventeen years, which is insufficient.

ISSUE

Whether the petitioners have acquired a vested right to register the land through acquisitive prescription, considering their possession commenced while the land was still classified as inalienable forest land.

RULING

The Supreme Court denied the petition and affirmed the decision of the Court of Appeals. The core legal principle is that possession of forest lands, no matter how long, cannot ripen into private ownership. For a grant under Section 48(b) of Commonwealth Act No. 141, the Public Land Act, the requisite thirty years of open, continuous, exclusive, and notorious possession must be computed from the time the land is officially declared alienable and disposable. Since the subject land was released from its forest classification only on January 23, 1968, the petitioners’ possession prior to that date is legally inconsequential. Their possession from 1968 to 1984 totals only seventeen years, failing to meet the statutory period.
The Court distinguished this case from Director of Forestry v. Villareal and similar rulings cited by the petitioners. In those cases, the applicants’ possession antedated the land’s classification as forest land, thereby creating vested rights that could not be impaired by subsequent state classification. Here, the possession began while the land was already forest land; thus, no such vested right existed before its reclassification. The petition was denied for lack of merit.