Primary Holding

Possession of forest lands, regardless of duration, cannot ripen into private ownership. Forest lands remain in the public domain and are not subject to registration for private individuals unless there is a positive act from the government declassifying them as agricultural or disposable land.

Background

The case originated from an application for land registration filed in the Court of First Instance of Capiz for Lot No. 885. Several oppositions were filed, including one from the Director of Forestry, who argued the land was forest land. The Court of First Instance partially granted the application to private litigants, but this was appealed.

Facts

• 1. Lot No. 885 of Pilar Cadastre, Capiz, with an area of 645,703 square meters was the subject of a land registration application.
• 2. Roque Borre and Melquiades Borre initially applied for registration.
• 3. Heirs of Jose Amunategui opposed and also sought registration of a portion (527,747 sq m).
• 4. Director of Forestry opposed, stating the land was mangrove swamp, classified as forest land and part of the public domain.
• 5. Emeterio Bereber also opposed, claiming a portion (117,956 sq m) for himself.
• 6. Roque Borre sold his rights to Angel Alpasan, who also opposed.
• 7. Evidence showed the land was classified as forest land since at least 1925, requiring timber licenses even for Jose Amunategui.
• 8. The land was converted to a fishpond around 1950 after a warning from the District Forester about its forest land classification.

Arguments of the Petitioners

• 1. Lot No. 885 is a "mangrove swamp," not thickly forested, and should not be classified as forest land in the traditional sense.
• 2. Even if it is a mangrove swamp (considered forest land under Revised Administrative Code), no large trees classified as first, second, or third groups are present.
• 3. Lot No. 885 has been in the actual possession of private persons for many years.
• 4. The land is already "private land," better suited and more valuable for agriculture than forestry and not needed for public forest interests.
• 5. Trial court committed grave abuse of discretion in dismissing Borre's complaint against Heirs of Amunategui (related to the sale of Lot No. 885 rights).
• 6. Court of Appeals exceeded its jurisdiction in ruling on the relative rights of private litigants after declaring the land as public domain.

Arguments of the Respondents

• 1. Lot No. 885 is classified as forest land, specifically mangrove swamp, which falls under the definition of forest land according to the Revised Administrative Code.
• 2. The land has been consistently treated as forest land by the Bureau of Forestry since at least 1925.
• 3. Private possession, no matter how long, cannot convert forest land into private property or make it registrable.
• 4. No positive government action has declassified Lot No. 885 from forest land to disposable agricultural land.

Issues

• 1. Is Lot No. 885 public forest land, and therefore not capable of private registration?
• 2. Can long-term possession of forest land by private individuals convert it into private property subject to registration?
• 3. Did the Court of Appeals err in declaring the land as public domain and dismissing all private applications for registration?

Ruling

• 1. The Supreme Court ruled in favor of the Director of Forestry, affirming the Court of Appeals.
• 2. The Court held that Lot No. 885 is indeed forest land and part of the public domain.
• 3. Classification as forest land is a legal status that does not depend on the presence of large trees or forest cover at the time of application.
• 4. Possession of forest lands does not ripen into private ownership because the statute of limitations does not run against the State regarding public lands.
• 5. A positive act from the government is required to declassify forest land into disposable agricultural land before it can be subject to private ownership and registration.
• 6. Since Lot No. 885 remained classified as forest land, the applications for registration were correctly dismissed.

Doctrines

• 1. Regalian Doctrine: All lands not privately owned belong to the State (implicitly invoked as the basis for public domain classification).
• 2. Immutability of Forest Land Classification: Land classified as forest land remains so unless officially declassified by a positive act of government.
• 3. Non-Ripening of Forest Land into Private Ownership by Prescription: Possession of forest land, no matter how long, cannot confer private title against the State.
• 4. Need for Positive Government Action for Declassification: Forest lands must be officially declassified to become alienable and disposable and thus subject to private ownership and registration.

Key Excerpts

• 1. "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."
• 2. "Unless and until the land classified as 'forest' is released in an official proclamation to that effect so that it may form part of the disposable agricultural lands of the public domain, the rules on confirmation of imperfect title do not apply."
• 3. "Possession of forest lands, no matter how long, cannot ripen into private ownership."
• 4. "It bears emphasizing that a positive act of Government is needed to declassify land which is classified as forest and to convert it into alienable or disposable land for agricultural or other purposes."

Precedents Cited

• 1. Director of Forestry v. Muñoz (23 SCRA 1184): Cited as a leading case establishing that possession of forest lands cannot ripen into private ownership.
• 2. Republic v. Animas (56 SCRA 499): Used to reinforce the principle that patents and titles over forest lands are void ab initio because forest land is not disposable public land.
• 3. Republic v. Gonong (118 SCRA 729): Cited to reiterate the principle from Oh Cho v. Director of Lands that land not acquired from the government belongs to the public domain, with limited exceptions not applicable in this case.
• 4. Republic v. Vera (120 SCRA 210): Cited to support the principle that possession of public land, including forest land, does not confer title due to the statute of limitations not running against the State.
• 5. Oh Cho v. Director of Lands (75 Phil. 890): Cited as precedent for the principle that all lands not acquired from the government are public domain.
• 6. Director of Lands v. Reyes (68 SCRA 177, 195): Cited in Republic v. Vera to support the principle that possession of public land must be under a claim of ownership for the required period to constitute a grant from the State.

Statutory and Constitutional Provisions

• 1. Section 1820, Revised Administrative Code: Defines "forest land" and includes mangrove swamps within its classification.
• 2. Section 1821, Revised Administrative Code: Classifies trees into groups, mentioned by petitioners but found irrelevant to the forest land classification of Lot No. 885.
• 3. Section 48, Commonwealth Act No. 141 (as amended by Republic Act No. 1942): Relates to the requirements for confirmation of imperfect title, which the Court found inapplicable to forest land.
• 4. Act No. 496 (Land Registration Act): Referred to by petitioners as the basis for land registration, but the Court held it cannot apply to forest lands.