Primary Holding

The Supreme Court reversed the Court of Appeals and Regional Trial Court decisions, holding that the Land Registration Court lacked jurisdiction to register inalienable public land, specifically land within a military reservation, and that the land titles obtained through fraudulent applications are void ab initio and must be cancelled.

Background

President Quezon issued Proclamation No. 265 in 1938, reserving land for military purposes, creating Camp Evangelista. Despite this, the Bacases and Chabons filed separate land registration applications in 1964 and 1974, respectively, for parcels within the reservation. The Land Registration Court granted their applications, leading to Original Certificates of Title. The Republic then filed actions to annul these titles.

Facts

• 1. In 1938, President Quezon issued Proclamation No. 265, reserving specific parcels of public land for military use as Camp Evangelista.
• 2. Despite the proclamation, the Bacases and Chabons applied for land registration for parcels of land within the military reservation.
• 3. In their applications, the Bacases mentioned the Philippine Army's occupancy but characterized it as "mere tolerance." The Chabons did not mention any military occupancy.
• 4. The Land Registration Court granted both applications, leading to the issuance of OCT No. O-358 (Bacases) and OCT No. O-669 (Chabons).
• 5. The Republic, upon discovering the titles, filed annulment cases, arguing fraud and lack of jurisdiction of the LRC, as the land was inalienable public land due to the military reservation.
• 6. Both the RTC and CA ruled in favor of the Bacases and Chabons, citing substantial compliance, res judicata, and estoppel against the government.

Arguments of the Petitioners

• 1. The Land Registration Court had no jurisdiction to register the lands because they were part of a military reservation and therefore inalienable public domain.
• 2. The respondents committed fraud by failing to fully disclose the military occupancy and the land's status as part of Camp Evangelista in their registration applications, thus depriving the Republic of its day in court.
• 3. The titles issued are null and void ab initio because they cover inalienable public land, and no amount of possession can ripen into private ownership.
• 4. The proviso in Proclamation No. 265 regarding “private rights” does not apply, as the respondents did not prove pre-existing private rights that predated the proclamation or that the land had been segregated from the reservation.

Arguments of the Respondents

• 1. There was substantial compliance with registration requirements because they mentioned Camp Evangelista as an occupant.
• 2. The Republic was not prejudiced as it had the opportunity to oppose and participate in the land registration proceedings.
• 3. The Land Registration Court had jurisdiction to determine if private rights existed over the land, even within a reservation, as per the proviso in Proclamation No. 265.
• 4. The issue of registrability is res judicata because the LRC already decided in their favor, and the Republic failed to appeal within the prescribed period.
• 5. Presidential Proclamation No. 265 exempted lands with existing private rights, and their possession constituted such private rights.

Issues

• 1. Did the Land Registration Court have jurisdiction over the applications for registration of land within the Camp Evangelista Military Reservation?
• 2. Can the decisions of the Land Registration Court be questioned despite becoming final and executory, considering allegations of fraud and lack of jurisdiction?
• 3. Did the respondents have a registrable right over the subject parcels of land, considering they are within a military reservation?

Ruling

• 1. The Supreme Court ruled in favor of the Republic, finding that the Land Registration Court had no jurisdiction to decree registration of land within the military reservation as it was inalienable public domain.
• 2. The Court found that the respondents' applications were tainted with fraud due to their failure to properly disclose the military reservation and occupancy, which deprived the Republic of proper notice and opportunity to oppose.
• 3. The Court held that decisions decreeing registration of inalienable public land are null and void ab initio and can be challenged at any time, even after becoming final, and are not protected by res judicata or prescription.
• 4. The proviso in Proclamation No. 265 for "private rights" does not apply because the respondents failed to prove any valid pre-existing private rights acquired before the reservation, and mere possession of public land does not create private rights.
• 5. The Court emphasized that the fundamental rule is that public domain lands are inalienable unless explicitly declared otherwise by law, and military reservations fall under this category.

Doctrines

• 1. Doctrine of Inalienability of Public Domain: Public domain lands, particularly military reservations, are inalienable and not subject to private appropriation unless expressly declared alienable by law.
• 2. Jurisdictional Defect in Land Registration: A Land Registration Court has no jurisdiction to decree registration of inalienable public land, making any title issued void ab initio.
• 3. Extrinsic Fraud in Land Registration: Fraudulent concealment or misrepresentation in a land registration application, especially regarding occupancy and the nature of the land, constitutes extrinsic fraud that vitiates the proceedings and title.
• 4. Res Judicata and Void Judgments: Res judicata does not apply to judgments rendered by a court without jurisdiction; such judgments are void and can be attacked at any time.
• 5. Doctrine of Estoppel Against the Government: The government is generally not estopped by the mistakes or negligence of its officials, especially concerning public land.

Key Excerpts

• 1. "The Land Registration Court has no jurisdiction over non-registrable properties, such as public navigable rivers which are parts of the public domain, and cannot validly adjudge the registration of title in favor of private applicant."
• 2. "Well-entrenched is the rule that unless a land is reclassified and declared alienable and disposable, occupation in the concept of an owner, no matter how long, cannot ripen into ownership and be registered as a title."
• 3. "Land that has not been acquired from the government, either by purchase or by grant, belongs to the State as part of the public domain."

Precedents Cited

• 1. Republic v. Estonilo: Cited to establish that Lot 4318 was part of Camp Evangelista and for the interpretation of the "private rights" proviso in Proclamation 265.
• 2. Pinza v. Aldovino: Cited to support the argument that failure to disclose adjoining owners in land registration applications is a jurisdictional defect.
• 3. Director of Lands v. Abanilla: Cited regarding the nature and effect of fraud in land registration.
• 4. Fewkes vs. Vasquez: Cited to explain the purpose of notice to adjoining owners and occupants in land registration.
• 5. Collado v. Court of Appeals: Cited to reiterate that titles to inalienable public land are void ab initio.
• 6. Republic v. Court of Appeals and De Jesus: Cited regarding lands covered by reservation not being subject to entry.
• 7. Heirs of Mario Malabanan vs. Republic of the Philippines: Cited to emphasize the inalienability of public domain lands and that possession cannot ripen into ownership.
• 8. Director, Lands Management Bureau v. CA: Cited regarding tax declarations not being incontrovertible evidence of ownership.
• 9. Director, Lands Management Bureau v. Court of Appeals: Cited to emphasize that even without opposition, the applicant must prove absolute ownership for land registration.
• 10. Republic v. Court of Appeals: Cited for the doctrine that estoppel does not operate against the State due to mistakes of its officials.

Statutory and Constitutional Provisions

• 1. Presidential Proclamation No. 265: Established Camp Evangelista Military Reservation.
• 2. Section 21 of Act 496 (Land Registration Act): Governed the form and content of land registration applications at the time of filing.
• 3. Section 38 of Act No. 496 / Section 32 of Presidential Decree (P.D.) No. 1529: Related to the review of decrees of registration on the ground of fraud.
• 4. Section 15 of P.D. No. 1529 (Property Registration Decree): Requires disclosure of occupants and adjoining owners in land registration applications.
• 5. Commonwealth Act (C.A.) No. 141 (Public Land Act): Governed the disposition of public lands.
• 6. Section 48(b) of C.A. No. 141 (as amended by RA 1942): Defined the requirements for judicial confirmation of imperfect titles.
• 7. Section 64(e) of the old Revised Administrative Code: Provided the President's power to segregate lands.
• 8. Section 101 of the Public Land Act: Allows the State to seek cancellation of titles issued to private individuals.
• 9. Section 14, Chapter 4, Book III of the 1987 Administrative Code: Restated the President's power to declare military reservations.