Primary Holding

Forest lands and national parks are not subject to private appropriation; Spanish titles are not valid proof of ownership for unregistered lands after Presidential Decree No. 892.

Background

Private respondents filed a complaint for quieting of title, asserting ownership over land based on a Spanish title. The Republic of the Philippines argued that the land was part of a forest reserve and national park, making it inalienable public land not subject to private ownership. The trial court and the Intermediate Appellate Court initially ruled in favor of the private respondents.

Facts

• 1. Private respondents claimed ownership of 166 hectares of land in Lucban, Quezon, based on a document alleged to be a Spanish title originally issued to Bernardo Merchan.
• 2. The land is located within the "Mts. Banahaw-San Cristobal National Park," established by Proclamation No. 716 in 1941, superseding Proclamation No. 42 of 1921 which initially declared the area a forest reserve.
• 3. The Republic argued the land was inalienable public land due to its classification as a forest reserve and national park.
• 4. The Spanish document presented by private respondents was deemed by the Republic as a mere instrument of claimed possession, not a valid title demonstrating acquired ownership.

Arguments of the Petitioners

• 1. They acquired ownership of the land by virtue of a Spanish title allegedly issued to their predecessor-in-interest, Bernardo Merchan.
• 2. They are the rightful co-owners and possessors of the land since time immemorial through their predecessors-in-interest.

Arguments of the Respondents

• 1. They acquired ownership of the land by virtue of a Spanish title allegedly issued to their predecessor-in-interest, Bernardo Merchan.
• 2. They are the rightful co-owners and possessors of the land since time immemorial through their predecessors-in-interest.

Issues

• 1. Can land proclaimed as part of a forest reserve in 1921 and later a national park in 1941 be subject to private appropriation and registration?
• 2. Is the Spanish document presented by the private respondents a valid and sufficient title to prove ownership of the land?

Ruling

• 1. The Supreme Court ruled in favor of the Petitioner, Republic of the Philippines. It reversed the decision of the Intermediate Appellate Court and dismissed the private respondents' complaint. The Court held that the land, being classified as part of a forest reserve and national park, is inalienable public land and not susceptible to private ownership. The Spanish document presented was deemed insufficient to establish ownership, especially in light of Presidential Decree No. 892 which rendered Spanish titles ineffective as proof of ownership for unregistered lands after February 16, 1976.

Doctrines

• 1. Doctrine of Inalienable Public Land: Forest lands or forest reserves are not capable of private appropriation, and possession, no matter how long, cannot convert them into private property. This is based on the principle that the State owns all lands not otherwise appearing to be privately owned.
• 2. Presidential Decree No. 892 and the Status of Spanish Titles: After February 16, 1976, Spanish titles can no longer be considered valid evidence of land ownership for lands not registered under the Torrens system.

Precedents Cited

• 1. Vano v. Government of the Philippine Islands: Established the principle that possession of forest lands, however long, cannot convert them into private property.
• 2. Adorable v. Director of Forestry: Reaffirmed that forest lands are inalienable.
• 3. Director of Forestry v. Munoz: Further supports the inalienability of forest lands.
• 4. Republic v. De la Cruz, Director of Lands v. Reyes and Alinsunurin v. Director of Lands, Republic v. Court of Appeals (89 SCRA 648), Republic v. Animas, Director of Lands v. Court Of Appeals (133 SCRA 701), Republic v. Court of Appeals (135 SCRA 156), Director of Lands v. Rivas, Republic v. Court of Appeals (154 SCRA 476): These cases were cited collectively to reinforce the settled jurisprudence that forest lands or reserves are not subject to private appropriation and ownership.

Statutory and Constitutional Provisions

• 1. Proclamation No. 42 (October 14, 1921): Proclamation initially declaring the land as a forest reserve.
• 2. Proclamation No. 716 (May 26, 1941): Proclamation establishing the Mts. Banahaw-San Cristobal National Park, superseding Proclamation No. 42.
• 3. Presidential Decree No. 892 (effective February 16, 1976): Decree limiting the evidentiary value of Spanish titles for unregistered lands.