Federation of Coron, Busuanga, Palawan Farmer's Association, Inc. vs. Secretary of DENR

Unclassified lands of the public domain are presumed forest lands belonging to the State and are inalienable unless and until classified as alienable and disposable agricultural lands by the Executive Department through a positive act of government, consistent with the Regalian Doctrine that all public domain lands are State property and not subject to private ownership absent express classification and release.

Members of farmer associations in Coron and Busuanga, Palawan, had cultivated parcels of land for generations, some since the 1960s or earlier. In the 1980s and 2000s, these lands were placed under the coverage of the Comprehensive Agrarian Reform Program (CARP) for distribution to tenant-farmers. However, implementation was halted when the Department of Environment and Natural Resources (DENR) determined that the subject parcels were unclassified forest lands under Section 3(a) of Presidential Decree No. 705, the Revised Forestry Code, and therefore inalienable public domain property outside the scope of agrarian reform. The farmers, claiming decades of possession and cultivation, challenged the statutory provision itself as unconstitutional.

• The Parties: Petitioners are the Federation of Coron, Busuanga, Palawan Farmer's Association, Inc. (FCBPFAI), Samahan ng Magsasaka sa Sto. Nino (SAMMASA), Sandigan ng Mambubukid ng Bintuan Coron, Inc. (SAMBICO), and Rodolfo Cadampog, Sr., representing farmers in Palawan.
• The Lands: SAMBICO members occupied farmlands in Sitio Dipangan and Langka, Brgy. Bintuan, Coron, Palawan, totaling 1,752.4006 hectares titled under Mercury Group of Companies. SAMMASA members farmed lands in Brgy. Sto. Nino, Busuanga, Palawan, originally titled under Jose Sandoval.
• CARP Coverage: In 2002 (for SAMBICO) and 1980 (for SAMMASA), the Department of Agrarian Reform placed these lands under CARP coverage for distribution to farmers.
• Classification Dispute: In March 2014, DAR informed petitioners that CARP implementation would not proceed because DENR classified the lands as unclassified forest land under Section 3(a) of P.D. No. 705, making them inalienable government property under DENR jurisdiction, not DAR.
• Petitioners' Claim: Petitioners alleged they had farmed these lands for decades or generations, some predating the establishment of their barangay in the 1960s, and claimed vested rights of ownership through long possession and cultivation.
• Failure to Reclassify: Petitioners had not filed applications to have the lands reclassified from forest to alienable and disposable with the DENR.

• Unconstitutionality of Section 3(a): Section 3(a) of P.D. No. 705 violates the Philippine Bill of 1902 and the 1935, 1973, and 1987 Constitutions by retroactively converting unclassified lands into forest lands, thereby depriving millions of Filipino occupants of vested ownership rights.
• Presumption of Agricultural Character: Under the Philippine Bill of 1902, unclassified lands not covered by trees and not reserved as forest land should be presumed agricultural, not forest land.
• Locus Standi: Petitioners possess the requisite standing as recipients of CARP distribution and as occupants who would suffer direct injury from the enforcement of the assailed provision.
• Impediment to Land Reform: Section 3(a) renders CARP implementation impossible because it places vast tracts under State ownership as forest lands, making them unavailable for agrarian reform.

• Presumption of Constitutionality: Every statute enjoys a presumption of constitutionality; petitioners failed to overcome this heavy burden by showing a clear and unequivocal breach of the Constitution.
• Lack of Locus Standi: Petitioners failed to substantiate claims of ownership or possession with evidence; bare assertions of CARP recipient status and occupation are insufficient to establish actual or threatened injury traceable to the challenged provision.
• Regalian Doctrine: Section 3(a) is consistent with the Regalian Doctrine (Jura Regalia), which reserves all public domain lands to State ownership until classified as alienable and disposable by the Executive; unclassified lands are not ipso facto agricultural.
• No Vested Rights: Occupants of unclassified public lands possess no vested rights capable of violation, as such lands remain inalienable State property not susceptible to private appropriation or acquisitive prescription.

• Constitutionality of Section 3(a): Whether Section 3(a) of Presidential Decree No. 705, defining public forest as unclassified lands of the public domain, is unconstitutional for violating the Regalian Doctrine and depriving occupants of vested rights.
• Locus Standi: Whether petitioners possess the legal standing to challenge the constitutionality of Section 3(a) of P.D. No. 705.

• Locus Standi: Legal standing was not established. Aside from bare assertions of CARP recipient status and occupation, petitioners presented no evidence proving actual possession, ownership, or that they had applied for reclassification and been denied; thus, no actual or threatened injury traceable to the challenged provision was demonstrated.
• Constitutionality of Section 3(a): Section 3(a) of P.D. No. 705 is constitutional. The provision merely codifies the Regalian Doctrine embodied in Article XII, Section 2 of the 1987 Constitution (and predecessor constitutions) that all lands of the public domain belong to the State. Unclassified lands remain State property and are inalienable unless and until positively classified as alienable and disposable agricultural lands by the Executive Department. The classification of public lands is an exclusive executive function under Commonwealth Act No. 141, not a judicial one.
• Presumption of State Ownership: All lands not clearly under private ownership are presumed to belong to the State. The burden of proving a land is alienable and disposable rests upon the applicant, who must show a positive act of government (presidential proclamation, executive order, administrative action, or legislative act) classifying the land as such.
• Nature of Forest Lands: Forest lands need not be actually covered with trees; the classification describes legal status, not physical appearance. Lands classified as forest remain so unless officially released by proclamation.

• Regalian Doctrine (Jura Regalia) — All lands of the public domain belong to the State, which is the source of any asserted right to ownership and is charged with the conservation of such patrimony. All lands not clearly within private ownership are presumed to belong to the State. Public lands remain inalienable unless the State positively reclassifies or alienates them to private persons. Native title (pre-conquest ownership by indigenous cultural communities) constitutes the sole exception.
• Presumption of Constitutionality — Courts afford deference to statutes enacted by the legislature and approved by the executive; the burden rests upon the party assailing the law to prove its invalidity beyond reasonable doubt with a clear and unequivocal showing of constitutional breach.
• Locus Standi Requirements — A party challenging governmental action must demonstrate a personal and substantial interest in the case, showing actual or threatened injury fairly traceable to the challenged conduct and likely to be redressed by a favorable decision. Mere incidental or consequential interest is insufficient.
• Exclusive Executive Power to Classify Lands — Under Commonwealth Act No. 141, the President (and through delegation, the Secretary of DENR) possesses the exclusive prerogative to classify lands of the public domain into alienable/disposable, timber, or mineral lands. Courts lack authority to classify lands in the absence of executive action.
• Unclassified Lands as Inalienable — Lands of the public domain that remain unclassified are presumed forest lands belonging to the State and are not susceptible to private appropriation, registration, or acquisitive prescription until positively classified as alienable and disposable by the Executive.

• "Every statute has in its favor the presumption of constitutionality. This presumption is rooted in the doctrine of separation of powers which enjoins upon the three (3) coordinate departments of the government a becoming courtesy for each other's acts." — Articulating the basis for judicial deference to legislative acts.
• "Pursuant to the Regalian Doctrine (Jura Regalia), a legal concept first introduced into the country from the West by Spain through the Laws of the Indies and the Royal Cedulas, all lands of the public domain belong to the State. This means that the State is the source of any asserted right to ownership of land, and is charged with the conservation of such patrimony." — Defining the foundational principle of State ownership.
• "Since 1919, courts were no longer free to determine the classification of lands from the facts of each case, except those that have already became private lands. Act No. 2874, promulgated in 1919 and reproduced in [Sec] 6 of [C.A.] No. 141, gave the Executive Department, through the President, the exclusive prerogative to classify or reclassify public lands into alienable or disposable, mineral or forest." — Establishing the transfer of classification authority from courts to the executive branch.
• "Forests, in the context of both the Public Land Act and the Constitution classifying lands of the public domain into 'agricultural, forest or timber, mineral lands, and national parks', do not necessarily refer to large tracts of wooded land or expanses covered by dense growths of trees and underbrushes. A forested area classified as forest land of the public domain does not lose such classification simply because loggers or settlers may have stripped it of its forest cover." — Clarifying that forest land classification is a legal status, not dependent on physical tree cover.
• "Unless public land is shown to have been reclassified as alienable or disposable to a private person by the State, it remains part of the inalienable public domain. Property of the public domain is beyond the commerce of man and not susceptible of private appropriation and acquisitive prescription. Occupation thereof in the concept of owner no matter how long cannot ripen into ownership and be registered as a title." — Stating the inalienability of unclassified public lands.

• Heirs of the late Spouses Vda. de Palanca v. Republic, 531 Phil. 602 (2006) — Followed for the holding that unclassified land cannot be considered alienable and disposable pursuant to the Regalian Doctrine.
• The Secretary of the Department of Environment and Natural Resources v. Yap, 589 Phil. 156 (2008) — Followed for the proposition that the presumption of agricultural classification under early cases (Ankron, Ramos) was superseded by legislation vesting classification power in the Executive.
• Cariño v. Insular Government, 212 U.S. 449 (1909) — Cited for the native title exception to the Regalian Doctrine, recognizing pre-conquest private ownership by indigenous communities.
• Republic v. Cosalan, G.R. No. 216999, July 4, 2018 — Cited for the definition of native title as pre-conquest rights held under claim of private ownership since time immemorial.
• Heirs of Malabanan v. Republic, 717 Phil. 141 (2013) — Cited regarding the social implications of land classification and the need for legislative action to regularize informal settlements.
• Republic v. Heirs of Sin, 730 Phil. 414 (2014) — Followed for the requirement of a positive act of government to prove land is alienable and disposable.

• Section 3(a), Presidential Decree No. 705 (Revised Forestry Code of the Philippines) — Defines "public forest" as the mass of lands of the public domain not subject to the present system of classification; applied as the assailed provision upheld as constitutional.
• Article XII, Section 2, 1987 Constitution — Embodies the Regalian Doctrine that all lands of the public domain belong to the State; cited as the constitutional basis for State ownership of unclassified lands.
• Section 6, Commonwealth Act No. 141 (Public Land Act) — Vests in the President the authority to classify lands of the public domain into alienable/disposable, timber, and mineral lands; cited as the statutory basis for exclusive executive classification power.
• Section 12 and Section 13, Philippine Bill of 1902 — Section 12 placed property acquired by the U.S. under treaty with Spain under government control; Section 13 authorized the government to classify public lands; cited to show the historical evolution of classification authority and the absence of any presumption that unclassified lands are agricultural.

Peralta, C.J., Perlas-Bernabe, Leonen, Caguioa, Gesmundo, Reyes, Jr., Hernando, Carandang, Lazaro-Javier, Inting, Zalameda, Lopez, Delos Santos, Gaerlan, and Baltazar-Padilla, JJ.