GR L 37995; (September, 1987) (Digest)
G.R. No. L-37995 August 31, 1987
BUREAU OF FORESTRY, BUREAU OF LANDS and PHILIPPINE FISHERIES COMMISSION, petitioners, vs. COURT OF APPEALS and FILOMENO GALLO, respondents.
FACTS
Filomeno Gallo applied for the registration of four parcels of land in Buenavista, Iloilo, with a total area of 30.5943 hectares. He derived his claim from a predecessor-in-interest. The Director of Lands, the Director of Forestry, and the Philippine Fisheries Commission opposed the application. The trial court ordered the registration of the lands in Gallo’s name, excluding a portion identified as a municipal hall site. The Court of Appeals affirmed this decision. The petitioners appealed, contending that a significant portion (19.4080 hectares) of the applied land was classified as timberland or forest land based on official maps and a certification from the Director of Forestry, and was therefore inalienable.
ISSUE
Whether the courts can reclassify public lands, specifically from forest land to alienable agricultural land, based on evidence presented during registration proceedings, or if such classification is an exclusive prerogative of the Executive Branch.
RULING
The Supreme Court reversed the decisions of the lower courts. The legal logic is anchored on the principle of separation of powers and specific statutory authority. The classification of public lands into alienable or disposable, mineral, or forest lands is an executive function, not a judicial one. This authority is vested in the President, upon recommendation of the Secretary of Natural Resources (formerly the Secretary of Agriculture and Natural Resources), as provided under Section 6 of Commonwealth Act No. 141, the Public Land Act. The certification from the Director of Forestry, indicating the land was within a timberland block and needed for forest purposes, constitutes a valid executive classification. Courts cannot override this official determination by reclassifying the land based on possessory claims or physical characteristics alone. Consequently, the 19.4080 hectares, being officially classified as forest land, are inalienable and cannot be registered. Possession of forest lands, no matter how long, cannot ripen into private ownership. The Court, however, upheld the registration of the remaining 11.1863 hectares, which were admittedly within the disposable portion of the public domain.