G.R. No. 95608 January 21, 1997
Spouses Ignacio Palomo and Trinidad Pascual, and Carmen Palomo Vda. De Buenaventura, petitioners, vs. The Honorable Court of Appeals, The Republic of the Philippines, et al., respondents.

FACTS

The petitioners claim ownership over 15 parcels of land in Tiwi, Albay, which form part of the area proclaimed as the Tiwi Hot Spring National Park. The property originated from titles allegedly issued to Diego Palomo in 1916-1917, based on decrees from the Court of First Instance of Albay. These lands were donated to his heirs, the petitioners, in 1937. After the original titles were reportedly lost, reconstituted titles were issued in the 1950s. The petitioners possessed the land, paid taxes, and introduced improvements. In 1954, President Magsaysay issued Proclamation No. 47, establishing the Tiwi Hot Spring National Park over the same area reserved by Executive Order No. 40 in 1913. The Republic subsequently filed an action for annulment of the petitioners’ certificates of title.

ISSUE

The core issue is whether the petitioners acquired valid and indefeasible title to the subject parcels of land, which were part of a public forest reservation later proclaimed as a national park, rendering them inalienable public domain.

RULING

The Supreme Court denied the petition and affirmed the lower courts’ decisions declaring the petitioners’ titles null and void. The legal logic is anchored on the fundamental principle that no public land can be acquired by private persons unless it is first classified as alienable and disposable. Executive Order No. 40 in 1913 reserved the land for provincial park purposes, thereby segregating it from the public domain and rendering it non-alienable. The subsequent judicial decrees and titles issued in the name of Diego Palomo in 1916-1917 were therefore void from the beginning, as the land was not susceptible to private appropriation or registration at the time. The Court emphasized that the government’s act of reserving a tract of forest land for public use gives rise to a permanent right of ownership on its part, and such land is removed from entry, sale, or other disposition. The property’s later conversion into a national park in 1954 merely reinforced its inalienable status. Consequently, the reconstituted titles derived from the void original certificates of title are also void. The petitioners’ possession, tax payments, and introduced improvements cannot ripen into ownership or validate the defective titles over inalienable public land. The forfeiture of improvements in favor of the government was likewise upheld.