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NatRes Cases Digest

Case 1: The court held that the applicant's registration of title will not prosper because the parcels of land in question are public forest lands, which cannot be acquired through private appropriation unless declassified by the government. Case 2: The court held that while the property was alienable public land, the respondent failed to prove possession and ownership for the required period of time to constitute a grant from the state, as the claimant's cultivation was not sufficient, exclusive or notorious possession. The petition of the Republic of the Philippines was granted.

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2K views1 page

NatRes Cases Digest

Case 1: The court held that the applicant's registration of title will not prosper because the parcels of land in question are public forest lands, which cannot be acquired through private appropriation unless declassified by the government. Case 2: The court held that while the property was alienable public land, the respondent failed to prove possession and ownership for the required period of time to constitute a grant from the state, as the claimant's cultivation was not sufficient, exclusive or notorious possession. The petition of the Republic of the Philippines was granted.

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leclec05
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© Attribution Non-Commercial (BY-NC)
We take content rights seriously. If you suspect this is your content, claim it here.
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Case # 4 REPUBLIC OF THE PHILIPPINES VS CELESTINA NAGUIAT

(GR.NO. 134209, Jan. 24, 2006)

Case # 5 REPUBLIC OF THE PHILIPPINES VS CANDY MAKER, INC.


(GR.NO. 163766, June. 22, 2006)

Facts: This is an application for registration of title to four parcels of land by Celestina Nuguiat located at Botolan, Zambales. Applicant(respondent) alleges that she is the owner of the said parcels of land having acquired them by purchase from the LID Corporation which likewise acquired the same from Demetria Calderon, Josefina Moraga, and Fausto Monje and their predecessor in-interest who have been in possession thereof for more than 30 years. The Republic filed an opposition to the application on the ground that neither the applicant nor her predecessors-in-interest have been in open, continuous, exclusive and notorious possession and occupation of the lands in question since June12, 1945 or prior thereto; that the monuments of title and tax payment receipts of applicant do not constitute competent and sufficient evidence of a bonafide acquisition of the lands applied for, and that the parcels of land applied for are part of the public domain belonging to the Republic of the Philippines not subject to private appropriation. Facts: On April, 29, 1999, Antonia, Eladia, and Felisa, all surnamed Cruz, executed a Deed of Absolute Sale in favor of Candy Maker, Inc. for a parcel of land located below the reglementary lake elevation of 12.50m, about 900 meters away the Laguna de Bay. Candy Maker, Inc. as applicant, filed an application with the MTC of Taytay, Rizal for registration of its alleged title over the lot. The CENRO of Antipolo City declared the land to fall within the alienable and disposable zone. On the otherhand, the Land Registration Authority recommended the exclusion of lot no. 3138-B on the ground that it is a legal easement and intended for public use, hence, inalienable and indisposable. On July 2001, the Republic of the Philippines, the LLDA filed its opposition which alleged that the lot subject of the application for registration may not be alienated and disposed since it is considered part of the Laguna Lake Bed, a public land within, its jurisdiction.

Issue: Whether or not the areas in question have ceased to have the status of forest or other inalienable lands of the public domain and the applicants registration of title will prosper. Issue: Whether the property subject of the amended application is alienable and disposable property of the State, and if so, whether respondent adduced the requisite quantum of evidence to prove its ownership over the property?

Held: Applicants registration of title for said parcels of land will not prosper because the said land is a public forest lands. Forest lands unless declassified and released by positive act of the Government so that they may form part of the disposable and agricultural lands of the public domain, are not capable of private appropriation. Forests, in the context of both 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 a large tract of woodland or an expanse covered by dense growth of trees and underbrush. Here, respondent never presented the required certification from the proper government agency or official proclamation reclassifying the land applied for as alienable and disposable. For unclassified land, as here, cannot be acquired by adverse occupation thereof in the concept of owner, however long, cannot ripen into private ownership and be registered as title. Held: The property subject of this application was alienable and disposable public agricultural land. However, respondent failed to prove that it possesses registrable title over the property. The statute of limitations with regard to public agricultural lands does not operate against the statute unless the occupant proves possession and occupation of the same after a claim of ownership for the required number of years to constitute a grant from the State. A mere casual cultivation of portions of the land by the claimant does not constitute sufficient basis for a claim of ownership, such possession is not exclusive and notorious as to give rise to presumptive grant from the state. In light of the foregoing, the petition of the Republic of the Philippines is granted.

Iloisa C. Collamar- Natural Resources Iloisa C. Collamar- Natural Resources

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