Director of Forest Administration vs.

Fernandez
Facts:
On August 28, 1943, private respondent Eugenia Soriano de Gomez, represented by her husband Teodoro Y. Gomez, filed before the Court of First Instance of Pangasinan an
application for the registration of her titles to eleven (11) parcels of land situated in the municipality of Mangatarem, Pangasinan, to wit: Lots 1, 2, 3 and 4 of Plan Psu-24384;
and Lots 1, 2, 3, 4, 5 and 6 of Plan Psu-114232, involving more than 2,000 hectares of land which application was amended on October 28, 1943 to reflect the
requirements of the Chief Surveyor of the General Land Registration Office.
Aside from the Bureau of Forestry, the Bureau of Lands and the Reforestation Administration, there were about 71 oppositors and about 200 who signified their opposition
through their lawyer but failed to file their written oppositions.
The case was dismissed on March 1, 1951 for lack of interest on the part of applicant but was revived more than three years after when applicant thru counsel filed a motion for
reconsideration of the order of dismissal and the registration court on July 26, 1954 issued an order setting aside the order of dismissal.
On July 19, 1966, applicant Eugenia Soriano de Gomez died and was substituted by her children.
On January 30, 1968, counsel for applicants and counsel for the private oppositors filed a joint manifestation and motion withdrawing all the private oppositions in the case.
Issue:
W/N the registered possessory information ripens into ownership.
Held:
under Article 393 of the Spanish Mortgage Law, the registered possessory information proceedings do not ripen into ownership except under certain conditions such as: (a) that
an applicant has been in open possession of the land; (b) that an application to this effect has been filed after the expiration of twenty (20) years from the date of such
registration; (c) that such conversion be announced by means of a proclamation in a proper official bulletin; (d) that there is a court order for the conversion of the
registration of possession into a record of ownership; and (e) that the Register of Deeds make the proper record thereof in the Registry (Querol v. Querol, 48 Phil.
90; Fernandez Hermanos v. Director of Lands, supra; Director of Lands v. Reyes, 68 SCRA 137 [1975]). cdll
In the case at bar, none of these requisites have been complied with, Jose Soriano y Ventanilla in whose name the informacion posesoria was issued and from whom private
respondents trace their right over the property by inheritance, died in 1910 (TSN, Nov. 20, 1962; p. 4; TSN, June 18, 1963; p. 63; TSN, Sept. 10, 1963, p. 105) only fifteen years
after the inscription of the titulo de informacion posesoria in the registry of property and therefore could not have converted the same into a record of ownership twenty years
after. Furthermore, the Royal Decree of February 13, 1894 known as the Maura Law, which granted the right to perfect possessory informacion posesoria title under the law
expired one year after its promulgation or on April 17, 1895, the very day the titulo de informacion posesoria was entered in the registry of property. After its expiration, full
property rights over the land reverted to the government and the right of the cultivator and possessor to obtain gratuitous title was extinguished (Baltazar v. Insular Government,
40 Phil. 267 [1919]; Director of Lands v. Reyes, 68 SCRA 177 [1975]). It is, therefore, indisputable that the registration of possession had not been converted into a
registration of ownership in accordance with Article 393 of the Spanish Mortgage Law. Consequently, private respondents do not possess a registerable title
(Fernandez Hermanos v. Director of Lands,supra). As held by this Court, failure to perform all conditions essential to a government grant does not entitle an applicant to
confirmation of an imperfect title (Director of Lands v. Datu, 115 SCRA 25 [1982]). At most, the titulo de informacion posesoria in the instant case may provide a prima
facie evidence of the fact that at the time of its execution the predecessors-in-interest ofclaimants were in possession of the property covered, which may possibly be converted
into ownership by uninterrupted possession for the statutory period (Baltazar v. Insular Government, supra; Republic v. IAC, 148 SCRA 480 [1987]).
Director of Lands vs IAC
Facts:
The application for the registration of said lot, which allegedly contained an area of 1,036,172 square meters, was filed by Espartinez on May 17, 1972. He alleged therein that
he acquired lot by purchase from Sotera Llacer. He invoked Section 48 ofCommonwealth Act No. 141, as amended by Republic Act No. 1942, should the Land Registration Act
be not applicable.
The jurisdictional requirements of publication of notice of initial hearing (Exhibits "A" and "C") and posting of such notices in conspicuous places in the parcel of land involved
and in the municipal building (Exhibit "B") having been complied with, and considering that only the Bureau of Lands and the Bureau of Forestry represented by the fiscal had
appeared, the lower court issued an order of general default with the exception of said government agencies. Thereafter, one Perpetua Llarena appeared and, together with the
fiscal, she was required to file an opposition to the application.
Inasmuch as both the fiscal and Llarena failed to file their respective oppositions within the period set by the court, on December 12, 1972, it commissioned the clerk of court to
receive evidence. On the same day, however, the Solicitor General entered his appearance for the government and at the same t ime, filed an opposition to the application for
registration. He alleged therein that neither Espartinez nor his predecessors-in-interest had sufficient title to acquire ownership in fee simple of the land the same not having
been acquired by means of any of the various types of title issued by the Spanish government or any other recognized mode of acquisition of title over realty under pertinent
laws; that neither Espartinez nor his predecessors-in-interest were in open, continuous, exclusive and notorious possession of the land for at least thirty (30) years prior to the
filing of the application; that Espartinez may not avail of the provisions of Section 48 of the Public Land Act for failure to fulfill the requisites prescribed therein; and that the
parcel of land involved is part of the public domain and therefore, not subject to private appropriation.
Thereafter, seventeen (17) oppositors, claiming to be farmer-settlers on the land, filed a motion to lift the order of general default and opposition to the application for
registration. Espartinez filed a motion to dismiss the opposition contending that the private oppositors were, with one exception, mere homestead applicants who were barred by
prior judgments in Civil Case No. 2976, which was dismissed for failure to prosecute, and in CAR Case No. 523 wherein the Court of Agrarian Relations declared Sotera Llacer
as the owner of Lot 6783 and the oppositors as her tenants.
Issue:
W/N tax declarations or tax receipts are conclusive evidence of ownership.
Held:
Tax declarations or realty tax payments of property are not conclusive evidence of ownership.
The survey plan, Exhibit "M", which allegedly evidences the fact that the land actually contains an area of around 103 hectares instead of the 80 hectares reflected in Exhibit "L",
is not even admissible in evidence because it has not been approved by the Director of Lands.
Espartinez having failed to present any proof that the land in question has been classified as and forms part of the disposable publ ic domain, whatever possession he might
have had, and however long, cannot ripen into private ownership.|||
Republic vs Court of Appeals (1984)
Facts:
The lot subject matter of this land registration case, with an area of 17,311 square meters, is situated near the shore of Laguna de Bay, about 20 meters therefrom in Barrio
Pinagbayanan, Pila Laguna. It was purchased by Benedicto del Rio from Angel Pili on April 19, 1909. When Benedicto died in 1957, his heirs extrajudicial partitioned his est ate
and the subject parcel passed on his son, Santos del Rio, as the latters share in the inheritance.
Sometime before 1966, private oppositors obtained permission from Santo to construct duck houses on the land in question. Although there was no definit e commitment as to
rentals some of them had made voluntary payments to Santos. In violation of the original agreement, private oppositors constructed residential houses on the land, which
prompted Santos to file an ejectment against the private oppositors. Meanwhile, during the latter part of 1965, private oppositors had simultaneously filed their respective sales
application with the Bureau of Lands and was opposed by Santos.
Issue:
W/N the applicant-private respondent has a registrable title to the land.
Held:
Private persons cannot reclaim land from public waters without prior permission by the government and, even if reclamation is authorized, acquisition thereof for ownership is
not automatic. The claim of private oppositors, that they have reclaimed the land from the waters of Laguna de Bay and that t hey have possessed the same for more than 20
years does not improve their position. In the first place, private persons cannot, by themselves reclaim land from water bodies belonging to the public domain without proper
permission from the government authorities. And even if such reclamation had been authorized, the reclaimed land does not automatically belong to the party reclaiming the
same as they may still be subject to the terms of the authority earlier granted. Private oppositors failed to show proper authority for the alleged reclamation therefore; their
claimed title to the litigated parcel must fall.
Republic vs CA (1988)
Facts:
It is the policy of the State to encourage and promote the distribution of alienable public lands as a spur to economic growth and in line with the social justice ideal enshrined in
the Constitution. At the same time, the law imposes stringent safeguards upon the grant of such resources lest they fall into the wrong hands to the prejudice of the national
patrimony. prLL
This policy is involved in the case at bar, which deals with the confirmation of an imperfect title over a tract of land allegedly owned by the private respondent. The land is
situated in Barrio San Miguel, Municipality of Jordan, Sub-province of Guimaras, in the Province of Iloilo, and consists of 181.4776 hectares. 1 On December 29, 1976,
Romerico Chavez filed an application for its registration 2 with the Court of First Instance of Iloilo. 3 Only the Director of Lands opposed. After hearing, with the applicant as the
lone witness, the application was granted. 4 The petitioner then appealed to the Court of Appeals 5 which affirmed the decision but reduced the area of the grant to 144
hectares as the maximum allowable. 6 Disagreeing, the petitioner has come to this Court in this petition for certiorari under Rule 45 of the Rules of Court.
Issue:
W/N in confirmation of imperfect title, blue print copies are sufficient for identification.
Held:
In Republic of the Philippines v. Intermediate Appellate Court, where we held that while the best evidence to identify a piece ofland for registration purposes was the original
tracing cloth plan from the Bureau of Lands, blueprint copies and other evidence could also provide sufficient identification.
South City Homes, Inc. vs Republic
Facts:
The subject of this dispute is a strip of land between two lots owned by the petitioner. It has an area of 613 square meters and is situated in Calabuso, Bian, Laguna. It was
discovered only in 1983 after a survey conducted by the Bureau of Lands and is now identified as Lot No. 5005 of the Bian Estate. 1 Registration thereof in the name of the
petitioner was decreed in 1984 by the trial court pursuant to the Property Registration Law. 2 On appeal, the order was reversed by a special division of the respondent court,
with two members dissenting. 3 The petitioner is now before us, claiming that the reversal was erroneous.|||
Issue:
W/N petitioner acquired the lot in dispute.
Held:
The weakness of the petitioner's position prevents this Court from affirming the claim to the lot in question either as part of the two other lots or by virtue of
acquisitive prescription. And having made this ruling, we find it unnecessary to determine whether the land is patrimonial in nature or part of the public domain. cdrep
The case of Director of Lands v. Intermediate Appellate Court, 12 on which the petitioner relied so strongly (to the point of simply invoking it in a
supplemental petition instead of filing its memorandum), is not applicable. That decision, which reversed the case of Manila Electric Co. v. Castro-
Bartolome, 13 involved a situation where the public land automatically became private as a result of prescription clearly and indubitably established by the claimant. In
the case at bar, the petitioner's claim is rejected not because it is a private corporation barred from acquiring public land but because it has failed to establish its title to
the disputed lot, whatever its nature.