Collado vs. Court of Appeals
The petition seeking reversal of the Court of Appeals' annulment of a land registration decision was denied. Petitioners applied for confirmation of imperfect title over a 120-hectare lot in Antipolo, Rizal, claiming open, continuous possession since 1902. The trial court granted the application, but the Court of Appeals annulled the judgment for lack of jurisdiction, citing the lot's location within the Marikina Watershed Reservation. Affirming the appellate court, it was ruled that under the Regalian Doctrine, the lot is presumed public domain; petitioners failed to prove it was officially declassified as alienable and disposable. Possession of inalienable watershed land cannot ripen into private ownership, and petitioners' possession—whether counted before or after the watershed proclamation—did not satisfy the 30-year requirement under the Public Land Act.
Primary Holding
A watershed reservation remains inalienable public land, and possession thereof cannot ripen into private ownership, absent a positive executive act declassifying the land.
Background
On April 25, 1985, Edna T. Collado filed an application for registration of a 120.0766-hectare parcel of land situated in Barangay San Isidro, Antipolo, Rizal, covered by Survey Plan Psu-162620. The application was later amended to include co-applicants. Petitioners traced their claim of ownership to Sesinando Leyva, who allegedly had the property surveyed in his name on March 22, 1902, with the land subsequently transferred through a series of sales to the present petitioners. The Republic of the Philippines and the Municipality of Antipolo opposed the application. The technical description attached to the application itself stated that the survey was inside the Marikina Watershed.
History
-
Filed application for land registration in the Regional Trial Court of Antipolo, Rizal, Branch 71 (LRC No. 269-A)
-
RTC rendered decision confirming petitioners' imperfect title over the lot
-
Solicitor General filed a Petition for Annulment of Judgment in the Court of Appeals (CA-G.R. SP No. 25597)
-
Court of Appeals granted the petition and declared the RTC decision null and void
-
Petitioners filed a Petition for Review on Certiorari with the Supreme Court
Facts
- The Application and Claim of Possession: Petitioners anchored their application for confirmation of imperfect title on continuous possession since time immemorial. They presented evidence of nine transfers of rights starting from Sesinando Leyva in 1902, through intermediate owners, and eventually to the twenty-five co-applicants. They also submitted tax declarations and payment of real estate taxes.
- The Trial Court's Ruling: The RTC confirmed petitioners' imperfect title. It held that petitioners had acquired private rights to which the Marikina Watershed Reservation proclamation was subject. The RTC relied on a Bureau of Forest Development certification stating the area was excluded from the watershed per Proclamation No. 1283.
- Proclamation History and Conflicting Evidence: Executive Order No. 33 (1904) established the Marikina Watershed Reservation (MWR). Proclamation No. 1283 (1974) excluded a 3,780-hectare area (Lot A) from the MWR for townsite purposes. However, Proclamation No. 1637 (1977) amended Proclamation No. 1283, revising the technical descriptions and effectively reverting Lot A back to the MWR. Petitioners' evidence of declassification—a Bureau of Forest Development certification—was contradicted by a National Land Titles and Deeds Registration Administration report, a DENR Deputy Land Inspector letter, and the technical description attached to petitioners' own application, all confirming the lot remained inside the MWR.
Arguments of the Petitioners
- Private Rights and Presumption of Alienability: Petitioners argued that all presidential proclamations are subject to existing private rights, and their predecessor's possession since 1902 vested private rights before the issuance of EO 33. They contended that under the Philippine Bill of 1902 and Public Land Act No. 926, possession by private individuals created a legal presumption that the land was alienable and disposable.
- Subsequent Reclassification: Petitioners asserted that Proclamation No. 1283 subsequently segregated the lot from the public domain, making it alienable and disposable as a townsite under Commonwealth Act No. 141.
- Procedural Bars to Annulment and Intervention: Petitioners maintained that the Court of Appeals erred in giving due course to the Republic's petition for annulment of judgment, which was filed after the RTC decision had become final and executory. They argued that res judicata and estoppel barred the Republic, which had participated in the trial court proceedings. They further contended that the intervenors' petition was filed out of time.
Arguments of the Respondents
- Regalian Doctrine and Inalienability: Respondent Republic, through the Solicitor General, countered that under the Regalian Doctrine, all lands of the public domain belong to the State, and petitioners failed to present any evidence that the lot had been declared alienable and disposable. The lot's inclusion in the MWR rendered it inalienable.
- Lack of Jurisdiction: Respondent argued that the RTC lacked jurisdiction over inalienable public land, rendering its decision void and susceptible to annulment at any time.
- Intervenors' Interest: Respondent-intervenors, holders of DENR stewardship certificates, asserted that the lot was inalienable and that they were the actual occupants pursuant to Proclamation No. 585, which placed the area under the Integrated Social Forestry Program.
Issues
- Registrable Title: Whether petitioners possess registrable title over the lot, considering its location within a watershed reservation and the length of their possession.
- Annulment of Judgment: Whether the Court of Appeals erred in giving due course to the petition for annulment of judgment despite the RTC decision having become final.
- Intervention: Whether the Court of Appeals erred in allowing the petition-in-intervention filed after the RTC decision became final.
Ruling
- Registrable Title: No registrable title was acquired. The Regalian Doctrine presumes the lot belongs to the State; petitioners failed to overcome this presumption by clear and convincing evidence that the lot was officially declassified as alienable and disposable. A mere certification from the Bureau of Forest Development cannot override official proclamations and the technical description in petitioners' own application stating the lot is inside the MWR. Assuming the lot was alienable prior to 1904, Sesinando Leyva possessed it for only two years before EO 33, falling short of the 30-year period required under Section 48(b) of CA 141, as amended. After EO 33, the lot became inalienable, and possession thereof could no longer ripen into private ownership. Even if Proclamation No. 1283 temporarily excluded the lot, Proclamation No. 1637 reverted it back to the MWR, and petitioners' possession counted from 1974 would total only 11 years by the time of their application in 1985.
- Annulment of Judgment: The annulment was proper. The RTC never acquired jurisdiction over the inalienable public lot, rendering its decision void ab initio and attackable at any time. The principles of res judicata and estoppel do not apply to the State when asserting sovereign rights to recover inalienable public lands. Environmental concerns override procedural technicalities.
- Intervention: The intervention was properly allowed. While the Rules of Court generally require intervention before the rendition of judgment by the trial court, exceptions exist in the interest of substantial justice. The violent dispute between rival claimants and the need to settle the issue of the land's status warranted a relaxation of the rules.
Doctrines
- Regalian Doctrine — All lands not otherwise appearing to be clearly within private ownership are presumed to belong to the State. Applied to presume the lot in question is public domain, shifting the burden to petitioners to prove the land is alienable and disposable.
- Inalienability of Watershed Reservations — Watershed reservations are inalienable public lands; possession thereof, no matter how long, cannot convert the same into private property. Applied to bar petitioners' claim based on possession after the issuance of EO 33.
- Requirement of Positive Executive Act for Declassification — A positive act of the Executive Department (e.g., an official proclamation) is needed to declassify land classified as a watershed reservation and convert it into alienable or disposable land. Applied to reject petitioners' evidence of declassification, which consisted merely of a certification from the Bureau of Forest Development rather than an official proclamation.
- State Non-Estoppel and Imprescriptibility of Public Land Actions — Estoppel and res judicata do not apply to the State when suing as a sovereign to assert governmental rights, nor do they validate an act that contravenes law or public policy. The right of reversion to the State of public properties not capable of private appropriation does not prescribe. Applied to allow the Republic's petition for annulment of judgment despite the RTC decision having become final.
Key Excerpts
- "Once a parcel of land is included within a watershed reservation duly established by Executive Proclamation, as in the instant case, a presumption arises that the land continues to be part of such Reservation until clear and convincing evidence of subsequent declassification is shown."
- "Forest lands do not have to be on mountains or in out of the way places. Swampy areas covered by mangrove trees, nipa palms and other trees growing in brackish or sea water may also be classified as forest land. The classification is descriptive of its legal nature or status and does not have to be descriptive of what the land actually looks like."
- "Environmental consequences in this case override concerns over technicalities and rules of procedure."
Precedents Cited
- Cruz v. Secretary of Environment and Natural Resources, 347 SCRA 128 (2000) — Cited for the historical overview and adoption of the Regalian Doctrine in the 1935 Constitution, establishing state ownership of natural resources.
- Gordula v. Court of Appeals, 284 SCRA 617 (1998) — Applied as controlling precedent. It ruled that claiming "private rights" to exclude land from a forest reservation requires proving compliance with the Public Land Act, specifically the 30-year possession requirement, which petitioners failed to do.
- Municipality of Santiago, Isabela v. Court of Appeals, 120 SCRA 734 (1983) — Followed for the ruling that inalienable public lands cannot be acquired by acquisitive prescription and that prescription does not run against the State.
- Republic v. De los Angeles, 159 SCRA 264 (1988) — Applied to reject res judicata and estoppel as bars to the Republic's claim over public lands, holding that the right of reversion to the State does not prescribe.
- Heirs of Amunategui v. Director of Forestry, 126 SCRA 69 (1983) — Followed for the principle that the classification of land as forest is descriptive of its legal nature, not its actual appearance, and rules on confirmation of imperfect title do not apply until the land is officially released.
Provisions
- Section 48(b), Commonwealth Act No. 141 (Public Land Act), as amended by PD 1073 — Requires open, continuous, exclusive, and notorious possession of agricultural lands of the public domain under a bona fide claim of ownership for at least 30 years immediately preceding the filing of the application for confirmation of title. Applied to determine that petitioners' possession (2 years before 1904 and interrupted thereafter) was insufficient to vest a government grant.
- Section 9(2), Batas Pambansa Blg. 129 — Grants the Court of Appeals exclusive original jurisdiction over actions for annulment of judgments of Regional Trial Courts. Invoked as the procedural basis for the Republic's petition before the appellate court.
- Article 67, Water Code of the Philippines (PD 1067) — Authorizes the Department of Natural Resources to declare watersheds as protected areas and prohibit or control activities that may damage surface or ground water. Cited to underscore the State's policy of protecting watershed areas.
Notable Concurring Opinions
Vitug, Ynares-Santiago, JJ. Davide, Jr., C.J. (Chairman), on official leave.