FACTS:
The case involves the denial of the application for land registration filed by Mario Malabanan. He claimed to have purchased a parcel of land in Silang, Cavite, and sought registration of the land based on open, continuous, and adverse possession for more than 30 years. Malabanan presented a certification from the Department of Environment and Natural Resources (DENR) stating that the property was within the alienable and disposable land per Land Classification Map No. 3013. The Regional Trial Court (RTC) granted Malabanan's application, but the Court of Appeals (CA) reversed the decision. The CA held that possession prior to the classification of land as alienable and disposable should be excluded from the computation of the period of possession. Malabanan's heirs appealed the CA decision to the Supreme Court, arguing that prior possession of agricultural land should be counted in determining the period of possession. They also relied on previous rulings to support their argument. The Supreme Court denied the petition for review on certiorari, finding that Malabanan failed to establish sufficient evidence of possession and occupation of the property.
The case involves a motion for reconsideration filed by the petitioners and the Republic. The petitioners argue that the mere classification of the land as alienable or disposable should be deemed sufficient to convert it into patrimonial property of the State. They claim that the land in question had been possessed and occupied by them and their predecessors-in-interest since June 12, 1945, or earlier. They rely on previous rulings to support their argument.
On the other hand, the Republic seeks partial reconsideration to obtain clarification regarding the application of previous rulings. They contend that the decision has enlarged the interpretation of the Property Registration Decree through judicial legislation. They assert that an applicant is entitled to registration only when the land had been declared alienable and disposable since June 12, 1945 or earlier.
The court denies both motions for reconsideration and proceeds to discuss the different classifications of land in relation to land registration laws in the Philippines. They explain that land can be classified as either of public dominion or of private ownership. Land is considered of public dominion if it is intended for public use or belongs to the State for some public service or for the development of national wealth. Land belonging to the State that is not for public use or public service forms part of the patrimonial property of the State. Land that is not part of the patrimonial property of the State, provinces, cities, and municipalities is of private ownership if it belongs to a private individual.
The court further explains the Regalian Doctrine which states that all lands of the public domain belong to the State. Public lands remain part of the inalienable land of the public domain unless the State reclassifies or alienates them to private individuals.
The court also discusses the classification of public lands according to their alienability. The 1935 Constitution classified lands of the public domain into agricultural, timber, and mineral. The 1973 Constitution further classified them into seven categories, while the 1987 Constitution adopted the classification under the 1935 Constitution and added national parks. Only agricultural lands may be alienated, according to Section 2, Article XII of the 1987 Constitution.
In conclusion, the court states that alienable and disposable lands of the State fall into two categories: patrimonial lands of the State and lands of the public domain.
ISSUES:
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Whether only agricultural lands of the public domain may be alienated.
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Whether lands classified as forest or timber, mineral, or national parks are susceptible to alienation or disposition.
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Whether a positive act of the Government is necessary to enable the reclassification of non-agricultural lands for alienation.
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Whether a declaration of conversion must be made in the form of a law or presidential proclamation.
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Whether the Regalian Doctrine applies until the Executive Department exercises its prerogative to classify or reclassify lands.
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Whether possession by a Filipino citizen since June 12, 1945, or earlier, is required for the confirmation of imperfect or incomplete titles.
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Whether the land subject of the application for registration must have been already classified as agricultural land of the public domain for the provision of Section 48(b) of the Public Land Act to apply.
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Whether the classification or reclassification of the land as alienable and disposable agricultural land should have been made on June 12, 1945 or earlier.
RULING:
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Yes, only agricultural lands of the public domain may be alienated.
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No, lands classified as forest or timber, mineral, or national parks are not susceptible to alienation or disposition unless they are reclassified as agricultural.
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Yes, a positive act of the Government is necessary to enable the reclassification of non-agricultural lands for alienation.
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Yes, a declaration of conversion must be made in the form of a law or presidential proclamation.
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Yes, the Regalian Doctrine applies until the Executive Department exercises its prerogative to classify or reclassify lands.
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Yes, possession by a Filipino citizen since June 12, 1945, or earlier, is required for the confirmation of imperfect or incomplete titles.
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The court held that the classification required by Section 48(b) of the Public Land Act is classification or reclassification of a public land as agricultural. Thus, if there is no proof that the land is already classified as agricultural land of the public domain, the Regalian Doctrine applies and overcome the presumption that the land is alienable and disposable.
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The court ruled that the choice of June 12, 1945 as the reckoning point of the requisite possession and occupation was the sole prerogative of Congress. The court emphasized that Congress prescribed no requirement that the land subject of the registration should have been classified as agricultural since June 12, 1945, or earlier. Accordingly, the character of the property subject of the application as alienable and disposable agricultural land determines its eligibility for land registration, not the ownership or title over it.
PRINCIPLES:
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Only agricultural lands of the public domain may be alienated.
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Lands classified as forest or timber, mineral, or national parks are not susceptible to alienation or disposition unless they are reclassified as agricultural.
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A positive act of the Government is necessary to enable the reclassification of non-agricultural lands for alienation.
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A declaration of conversion must be made in the form of a law or presidential proclamation.
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The Regalian Doctrine applies until the Executive Department exercises its prerogative to classify or reclassify lands.
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Possession by a Filipino citizen since June 12, 1945, or earlier, is required for the confirmation of imperfect or incomplete titles.
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All lands of the public domain belong to the State and are inalienable, except those rendered alienable and disposable through the exclusive modes enumerated under Section 11 of the Public Land Act.
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The classification or reclassification of land as agricultural is required for Section 48(b) of the Public Land Act to apply.
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The choice of June 12, 1945 as the reckoning point for possession and occupation of land for purposes of land registration is the prerogative of Congress. The land need not have been classified as agricultural since June 12, 1945, to be eligible for land registration.
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The agricultural land subject of the application needs only to be classified as alienable and disposable as of the time of the application, provided the applicant's possession and occupation of the land dated back to June 12, 1945, or earlier.
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Proof that the land has been converted to private ownership prior to the requisite acquisitive prescriptive period is a condition sine qua non in observance of the law that property of the State not patrimonial in character shall not be the object of prescription.