G.R. No. L-43938, L-44081, L-44092. April 15, 1988.
Republic of the Philippines (Director of Forest Development), Benguet Consolidated, Inc., and Atok-Big Wedge Mining Company, petitioners, vs. Hon. Court of Appeals and Jose Y. de la Rosa, et al., respondents.

FACTS

Jose de la Rosa, on behalf of himself and his children, applied for the registration of nine parcels of land in Benguet, acquired from Mamaya Balbalio and Jaime Alberto. The applicants asserted ownership through their predecessors’ alleged open, continuous, and exclusive possession, supported by tax declarations and receipts. The application was opposed by the Republic, through the Bureau of Forestry Development, which argued the land was part of the inalienable Central Cordillera Forest Reserve. Mining companies Benguet Consolidated and Atok Big Wedge also opposed, asserting superior rights over the same land by virtue of perfected mining claims. Benguet’s “June Bug” claim was located and recorded in 1909, while Atok’s “Emma” and “Fredia” claims were located and recorded in 1931. Both companies presented evidence of extensive assessment work, improvements like tunnels, and consistent tax payments.
The trial court denied the registration application. On appeal, the Court of Appeals reversed, recognizing the de la Rosas’ surface rights over the land while simultaneously reserving the sub-surface mining rights of Benguet and Atok. This decision prompted the three separate petitions to the Supreme Court by the Republic and the two mining companies.

ISSUE

Whether the Court of Appeals erred in recognizing the de la Rosas’ registrable title to the land, given the prior vested rights of the mining companies and the land’s status as part of a forest reserve.

RULING

The Supreme Court reversed the Court of Appeals and reinstated the trial court’s denial of the application. The legal logic centers on the doctrine of vested rights and the application of mining laws prior to the 1935 Constitution. The mining claims of Benguet and Atok were located, perfected, and actively maintained under the Philippine Bill of 1902 and subsequent mining laws, which granted locators a valid and exclusive property right to the minerals and the land for mining purposes, even without a patent. These rights became vested long before the 1935 Constitution declared all public domain lands, except agricultural ones, inalienable.
Consequently, when the land was declared part of the Central Cordillera Forest Reserve in 1929, it could not impair these pre-existing vested rights. The de la Rosas’ claim of acquisition by prescription must fail because their predecessors could not have acquired alienable title to land that was, by operation of law, already subject to the exclusive mineral rights of the mining companies. The Regalian doctrine reserves mineral wealth to the State, but the State, through its laws, had already granted these specific rights to the mining locators. The ruling clarifies that such a perfected mining claim excludes simultaneous agricultural use, as the holder has the right to possess, extract, and utilize the land exclusively for mining.