G.R. No. L-71285 November 5, 1987
REPUBLIC OF THE PHILIPPINES, petitioner, vs. THE INTERMEDIATE APPELLATE COURT, ESTEBAN MENDOZA and LEON PASAHOL, respondents.

FACTS

Private respondents Esteban Mendoza and Leon Pasahol filed a petition to reopen the cadastral proceedings for Lot 444 in Mariveles, Bataan, seeking its registration in their names. They claimed ownership by purchase from the heirs of the original owners and asserted possession, tacked to their predecessors-in-interest, for over 30 years. Their predecessors failed to claim the lot during the original cadastral proceedings due to alleged lack of notice, leading to its declaration as public land, though it remained undisposed of by the government. The trial court initially denied registration due to procedural deficiencies but granted it upon reconsideration after respondents rectified these issues, a decision affirmed by the Intermediate Appellate Court.
The Solicitor General appealed, arguing that respondents’ possession commenced only in 1957 and could not be tacked to their predecessors’ possession because the latter failed to assert a claim during the cadastral proceedings. The State also contended that reopening under Republic Act No. 931 , as amended, is only permissible for lots declared public land due to absenteeism of the owner or his representative during the original proceedings, which was not the alleged reason here.

ISSUE

Whether the private respondents have sufficiently established a registrable title to Lot 444, justifying the reopening of the cadastral proceedings.

RULING

No. The Supreme Court reversed the appellate court’s decision and dismissed the application for registration. The legal logic centers on the indispensable requirement of alienability. For land to be registered under the Torrens system, it must first be classified as alienable and disposable agricultural land of the public domain. The Court found that the private respondents failed to present conclusive evidence, such as a positive certification from the proper government agency, that Lot 444 had been officially released as alienable. The certifications they submitted were insufficient to establish this crucial fact.
Furthermore, the Court clarified that a cadastral survey alone does not convert land into alienable property; it is merely a preparatory step for identification. Since the land remained unclassified, any possession by the applicants, regardless of length, could not ripen into private ownership. The State cannot be estopped by the omissions or errors of its officials regarding land classification. While expressing sympathy for the respondents’ long-term possession, the Court held their proper remedy is administrative, specifically to seek the official reclassification and release of the land from its current status. The petition for registration was thus dismissed without prejudice to that recourse.