G.R. No. L-68533. May 23, 1986.
DIRECTOR OF LANDS and DIRECTOR OF FOREST DEVELOPMENT, petitioners, vs. MARIANO FUNTILAR, MAGDALENA FUNTILAR, HEIRS OF FELIPE ROCETE and INTERMEDIATE APPELLATE COURT, respondents.

FACTS

The private respondents, grandchildren of Candida Fernandez, applied for registration of a 22.6773-hectare land in Mulanay, Quezon. They traced ownership to Fernandez, whose possession began before her death in 1936. The property, declared for taxes by her heirs, was forfeited for non-payment of taxes around 1940-1941 but was redeemed in 1942 by her son, Vitaliano Aguirre, who held it in trust for the co-heirs. After partition, the lot was adjudicated to the respondents, who subsequently declared it for taxation in 1948 and had it surveyed in 1965, revealing the corrected area. An ocular inspection found over a hundred coconut trees aged over thirty years. The Directors of Lands and Forest Development opposed, alleging the land was part of the public domain and that the applicants lacked registrable title, having neither a Spanish title nor the required thirty years of possession.

ISSUE

Whether the private respondents have acquired a registrable title to the subject land through open, continuous, exclusive, and notorious possession for the period required by law.

RULING

Yes. The Supreme Court affirmed the decisions of the lower courts, dismissing the petition. The legal logic centers on the application of the Regalian doctrine in conjunction with principles of social justice and the burden of proof in land registration cases. While all lands of the public domain belong to the State, the government oppositors failed to present any evidence to substantiate their claim that the land was part of the forest zone or inalienable. The Court emphasized that the burden to prove that a land is classified as forest or part of the public domain rests on the government. Here, the Directors of Lands and Forestry even submitted communications indicating they had no evidence to support their opposition and interposed no objection to the registration. Conversely, the private respondents established through unrebutted testimonial and documentary evidence that they and their predecessors-in-interest had possessed and cultivated the land for at least three generations, introducing permanent improvements like coconut trees. The land was certified alienable and disposable in 1953, and the respondents’ possession, which was open and continuous, well exceeded the required period. The Court held that the application enhanced the purpose of land registration laws, and the attempts of humble tillers to secure title to lands they have long cultivated should be encouraged, not thwarted by a rigid application of the Regalian doctrine absent contrary proof.