Primary Holding

Land reserved for public or quasi-public purposes remains inalienable public domain unless explicitly withdrawn from such reservation by law or presidential proclamation and positively declared alienable and disposable. A sale of inalienable public land is void ab initio, and the title issued based on such sale is also void.

Background

The land in question was originally part of Fort William McKinley, later Fort Andres Bonifacio Military Reservation (FBMR). Presidential Proclamation No. 423 reserved a large area for military purposes. Proclamation No. 461 excluded a portion as AFP Officers’ Village, intended for disposal under specific laws. Subsequently, Proclamation No. 478 reserved a smaller portion, including the property in dispute, for veterans rehabilitation. NOVAI claimed to have purchased the land from the Republic based on a Deed of Sale referring to a fictitious Proclamation No. 2487.

Facts

• 1. NOVAI holds TCT No. T-15387 for a 475,009 square-meter property within the former FBMR.
• 2. The land was initially part of a larger military reservation under Proclamation No. 423.
• 3. Proclamation No. 461 excluded a larger area from FBMR as AFP Officers' Village for disposal.
• 4. Proclamation No. 478 subsequently reserved a portion of the AFP Officers’ Village, including the subject property, for veterans rehabilitation.
• 5. In 1991, a Deed of Sale was executed between the Republic (represented by LMB Director Palad) and NOVAI, based on a purported Proclamation No. 2487.
• 6. The Republic filed a complaint to cancel NOVAI’s title, arguing the land was inalienable military reservation, the deed of sale was fictitious, and Proclamation No. 2487 was non-existent and fraudulent.
• 7. Evidence presented by the Republic included certifications from the Office of the President and NBI handwriting analysis concluding the deed of sale was forged and Proclamation No. 2487 did not exist in official records.
• 8. NOVAI claimed the property was alienable due to Proclamation No. 461, the deed of sale was valid, and Proclamation No. 2487 should be presumed valid.

Arguments of the Petitioners

• 1. The property is no longer public domain due to Proclamation No. 461, which segregated it from FBMR for disposition.
• 2. The Deed of Sale is valid and enforceable, executed by an authorized public officer with proper formalities.
• 3. Proclamation No. 2487 should be presumed valid, and the Republic failed to prove its forgery.
• 4. Testimony regarding the non-existence of Proclamation No. 2487 from another case was improperly considered.
• 5. The Republic’s action is barred by prescription because it was filed more than a year after the title issuance.
• 6. The Southside case is factually and doctrinally dissimilar and should not apply.

Arguments of the Respondents

• 1. The property is inalienable public land due to Proclamation No. 478, reserving it for veterans rehabilitation, overriding Proclamation No. 461.
• 2. Proclamation No. 2487 is non-existent and cannot be presumed valid without proof of authenticity and due execution.
• 3. The Deed of Sale is forged, as Director Palad denied signing it, and NBI confirmed forgery.
• 4. NOVAI, as a corporation, is disqualified from purchasing public land under relevant laws.
• 5. The Southside ruling is applicable due to factual and evidentiary similarities.
• 6. BCDA as intervenor argued NOVAI failed to comply with legal requirements for land release from military reservation and was incorporated after the deed of sale was purportedly executed.

Issues

• 1. Whether the property is alienable or inalienable public land.
• 2. Whether Proclamation No. 2487 legally exists and revoked Proclamation No. 478.
• 3. Whether the Deed of Sale to NOVAI is valid and enforceable or fictitious and void.
• 4. Whether the Republic’s action for cancellation of title is barred by prescription.
• 5. Whether the ruling in Republic v. Southside Homeowners Association, Inc. is applicable.

Ruling

• 1. The Supreme Court affirmed the CA decision, denying NOVAI's petition.
• 2. The Court ruled that the property remained inalienable public domain as it was reserved for veterans rehabilitation under Proclamation No. 478, which was the latest executive issuance.
• 3. Proclamation No. 2487, purportedly revoking Proclamation No. 478, was deemed non-existent due to lack of official records and contradictory evidence.
• 4. The Deed of Sale was declared void due to the non-existence of its legal basis (Proclamation No. 2487), forgery of Director Palad’s signature, and other irregularities surrounding the sale process.
• 5. Since the sale was void ab initio, the title issued to NOVAI was also void and did not become indefeasible. Prescription did not apply.
• 6. The Southside case was deemed applicable as both cases involved the invalid sale of land within former military reservations that remained inalienable public domain.

Doctrines

• 1. Public Domain Doctrine: Land classified as public domain, especially reservations for public or quasi-public use, is inalienable and not subject to private appropriation unless positively declared otherwise by the government.
• 2. Void ab initio: A contract or act that is void from the beginning, having no legal effect from its inception, such as the sale of inalienable public land.
• 3. Indefeasibility of Title: The principle that a Torrens title becomes incontrovertible after a certain period, but this principle does not apply when the title is void from the beginning, such as titles derived from void sales of public land.
• 4. Presumption of Regularity in Performance of Official Duties: While notarized deeds carry this presumption, it is disputable and does not apply when there is clear and convincing evidence to the contrary, such as in cases of forged documents and illegal transactions.
• 5. Intervention in Appeals: Intervention may be allowed even at the appeal stage if it is necessary to protect an interest that would otherwise be unprotected, and to fully serve justice, particularly when the intervenor is directly affected by the outcome of the case.

Key Excerpts

• 1. "Lands of the public domain classified as reservations for public or quasi-public uses are non-alienable and shall not be subject to disposition...until declared open for disposition by proclamation of the President."
• 2. "Any sale or disposition of property of the public dominion is void for being contrary to law and public policy."
• 3. "Since the sale of the property, in this case, is void, the title issued to NOVAI is similarly void ab initio."
• 4. "The rule on intervention, like all other rules of procedure, is intended to make the powers of the Court fully and completely available for justice x x x and aimed to facilitate a comprehensive adjudication of rival claims overriding technicalities on the timeliness of the filing thereof."

Precedents Cited

• 1. Republic of the Philippines v. Southside Homeowners Association, Inc.: Used as a precedent for similar cases involving cancellation of titles over land within military reservations that remained inalienable public domain.
• 2. Altres, et al. v. Empleo, et al. and Republic v. Medida: Cited to define questions of law and fact in certiorari petitions and the exceptions to the rule that factual findings of the CA are conclusive.
• 3. Development Bank of the Philippines v. Traders Royal Bank: Further elaborated on exceptions to the conclusivity of CA’s factual findings in Rule 45 petitions.
• 4. GSIS v. Court of Appeals and First Philippine Holdings Corporation v. Sandiganbayan: Cited regarding the purpose and nature of intervention.
• 5. Garcia, et al. v. David, et al. and Tahanan Development Corp. v. CA, et al.: Used in relation to the requirements for intervention, particularly the nature of the interest to be protected.
• 6. Pinlac v. Court of Appeals and Director of Lands v. Court of Appeals: Cited regarding the allowance of intervention even after judgment in exceptional circumstances.
• 7. Heirs of Mario Malabanan v. Rep. of the Philippines: Cited in the dissenting opinion of Justice Brion, but referenced in the main decision’s discussion on public domain.
• 8. Manila International Airport Authority v. Court of Appeals: Cited concerning the characteristics of property of public dominion.
• 9. Lozano v. Tabayag, Jr. and Republic v. Heirs of Felipe Alejaga, Sr.: Cited regarding the principle that registration does not vest title if the underlying sale is void.
• 10. Torbela v. Rosario: Further supports the principle that registration under the Torrens system merely confirms pre-existing title and does not validate void titles.
• 11. Delfin v. Billones: Cited concerning the disputable nature of the presumption of regularity in the performance of official duties.

Statutory and Constitutional Provisions

• 1. Section 1, Rule 45 of the Rules of Court: Governing petitions for review on certiorari to the Supreme Court, limited to questions of law.
• 2. Section 2, Rule 19 of the Rules of Court: Governing intervention in actions, allowing it before rendition of judgment by the trial court, with exceptions.
• 3. Commonwealth Act No. 141 (Public Land Act), Sections 6, 7, 8, 9, 83, 88: Provisions on classification, disposition, and reservation of public lands.
• 4. Republic Act No. 274 and Republic Act No. 730: Laws mentioned in Proclamation No. 461 for the disposal of AFP Officers' Village land.
• 5. Republic Act No. 7227 (Bases Conversion and Development Act of 1992): Created BCDA and transferred military reservations, subject to exemptions.
• 6. Article 419, 420, 421, 422 of the Civil Code: Classification of property into public dominion and private ownership, defining patrimonial property and properties for public use or service.
• 7. Act No. 3038, Sections 1, 2: Authorizing the Secretary of Agriculture to sell or lease private domain land, excluding public service land and limiting the Director of Lands' authority.
• 8. Batas Pambansa Blg. 878: Amended Public Land Act, limiting Director of Lands' authority to convey land up to ten hectares.
• 9. Rule 131, Section 3(k) of the Rules of Court: Presumption of regularity in the performance of official duties.