GR L 46145; (November, 1986) (Digest)
G.R. No. L-46145 November 26, 1986
REPUBLIC OF THE PHILIPPINES (BUREAU OF LANDS), petitioner, vs. THE HON. COURT OF APPEALS, HEIRS OF DOMINGO P. BALOY, represented by RICARDO BALOY, ET AL., respondents.
FACTS
The respondents, heirs of Domingo Baloy, applied for registration of a parcel of land based on a Spanish possessory information title and alleged continuous possession. The Director of Lands opposed, contending the land became irrevocably public domain under Act No. 627 . This law, enacted to establish a U.S. Naval Reservation, required private claimants within the reserved area to file their registration applications within six months from July 8, 1905; otherwise, their claims would be forever barred and the land conclusively adjudged public. Domingo Baloy did not file a claim within this period. The trial court denied the application, but the Court of Appeals reversed, approving registration.
ISSUE
The core issue is whether the respondents’ failure to file a claim within the statutory period under Act No. 627 automatically and conclusively converted the land into public domain, thereby barring their present application for registration.
RULING
The Supreme Court affirmed the Court of Appeals and granted registration to the respondents. The legal logic centers on strict compliance with statutory procedure and the nature of the U.S. Navy’s occupation. Act No. 627 , Section 3, mandated a specific judicial process: the Court of Land Registration must issue a notice, and only after the lapse of the period without a claim being filed would lands be “conclusively adjudged to be public.” The Court ruled this procedure is a requirement of due process, and such statutes in derogation of property rights must be strictly followed. There was no evidence presented that the Court of Land Registration ever issued the requisite judicial declaration or order conclusively adjudging this specific land as public. Court judgments cannot be presumed; their existence must be proven.
Furthermore, the Court upheld the appellate court’s finding that the Baloy family’s ownership was not lost. The U.S. Navy’s occupation from 1945 until its eventual abandonment was not in the concept of an owner but was merely transient, akin to a commodatum or temporary use. Such possession does not constitute the adverse, claim-of-ownership possession required for acquisitive prescription against the titled owner. The official communication from the Philippine government recognized the Baloy family’s historical title and possession, noting the interruption was only during the Navy’s temporary use. Therefore, the respondents’ registerable title, rooted in the valid Spanish-era possessory information, remained intact and was merely in a state of suspension during the Navy’s occupancy.