G.R. No. L-5159 January 30, 1953
CANAS PLANTATION COMPANY, petitioner-appellant, vs. BUREAU OF FORESTRY, oppositor-appellee.

FACTS

In April 1941, Canas Plantation Company purchased about 600 hectares of public land in Basilan from the Government through a sales application and award. It complied with the Public Land Law and paid the total price, with the last installment of P8,102.94 paid in Japanese military notes during the Japanese occupation. On August 17, 1948, the Director of Lands ordered the issuance of the patent, and Sales Patent No. V-166 was issued on August 19, 1948, leading to the issuance of Original Certificate of Title No. P-6 in the company’s name. The patent and title contained two conditions: (a) a first lien in favor of the Republic for P8,102.94, payable if the Japanese currency payment was declared invalid; and (b) a condition from the Director of Forestry that the timber land portion (199.68 hectares) shall remain with the Government. On May 25, 1951, Canas Plantation filed a petition in the Court of First Instance of Zamboanga to cancel these restrictions, arguing that Japanese currency payments had been validated by courts and that the forestry condition could not be imposed as it was not part of the original sale and the Director of Forestry had previously certified the land as alienable. The Bureau of Forestry opposed, contesting the court’s jurisdiction over the subject matter, claiming the land was still part of the public domain. The trial court sustained the objection and dismissed the petition, leading to this appeal solely on the issue of jurisdiction.

ISSUE

Whether the Court of First Instance had jurisdiction over the petition for cancellation of restrictions in the sales patent and certificate of title after their issuance.

RULING

Yes, the Court of First Instance had jurisdiction. The Supreme Court reversed the appealed decision and ordered the case remanded to the lower court for further proceedings. The Court held that after the sales patent and certificate of title were issued, the land ceased to be part of the public domain under the exclusive administration of the Department of Agriculture and the Government. Citing authorities, the Court ruled that the issuance of the patent transformed the land, and even if it had not entirely become private property, the petitioner acquired rights that the courts could protect. The Solicitor General, representing the Bureau of Forestry, conceded in his brief that the court had jurisdiction and agreed the case should be remanded.