GR L 58867; (June, 1984) (Digest)
G.R. No. L-58867 June 22, 1984
DIRECTOR OF LANDS and DIRECTOR OF FOREST DEVELOPMENT, petitioners, vs. HON. COURT OF APPEALS and ANTONIO VALERIANO, et al., respondents.
FACTS
Private respondents applied for judicial confirmation of title over a 9.3-hectare parcel of land in Obando, Bulacan, which they had converted into a fishpond. They claimed ownership through inheritance and purchase, asserting possession for over 30 years. The Republic, through the Director of the Bureau of Forest Development, opposed the application, contending the land was within an unclassified region per a 1927 forest map, thus constituting inalienable forest land. The trial court granted registration, a decision affirmed by the Court of Appeals, which found the respondents’ possession open and adverse and opined that a land devoted to fishpond purposes could not be categorized as forest land.
The parties stipulated that the land was within an unclassified region. A District Forester’s indorsement recommended its release for disposition, noting it was devoid of forest growth and fully developed as fishponds, but no official reclassification was presented. The petitioners argued that the courts could not reclassify public land and that possession of unclassified land cannot ripen into ownership.
ISSUE
Whether the courts can decree registration of land classified as part of the unclassified region of the public domain based on possession.
RULING
No. The Supreme Court reversed the lower courts’ decisions and dismissed the application for registration. The classification of public lands is an exclusive prerogative of the Executive Department, not the judiciary. Absent an official executive act reclassifying the land from unclassified or forest land to alienable and disposable agricultural land, it remains part of the inalienable public domain. The stipulation that the land was within an unclassified region was binding. The Regalian doctrine dictates that all lands of the public domain belong to the State, and the State cannot be estopped by the errors or omissions of its officials, such as the failure to formally present the 1927 map or the mere recommendation for release by a District Forester. Possession, however long, over land that is not yet classified as alienable cannot confer title. The cadastral survey of Obando did not automatically reclassify the land. The conversion into a fishpond and the existence of titled properties nearby do not alter its legal status. The proper remedy for the applicants is to seek the administrative release and reclassification of the land from the competent executive authorities. The Court, however, directed the petitioners to give serious consideration to such reclassification in fairness to the respondents.
