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REPUBLIC v. HEIRS OF MAXIMA LACHICA SIN

FACTS:

The case involves a dispute over a parcel of land in Barangay Tambac, New Washington, Aklan. The respondents claim to be the lawful heirs of Maxima Lachica Sin, who owned the land. They filed a complaint against the Aklan National College of Fisheries (ANCF) Superintendent for recovery of possession, quieting of title, and declaration of ownership with damages. The ANCF Superintendent argued that the land claimed by the respondents was subject to Proclamation No. 2074, which allocated the land as a civil reservation for educational purposes of the ANCF. The complaint was later amended to include the ANCF as a party defendant, and the case was remanded to the Municipal Circuit Trial Court (MCTC) of New Washington and Batan, Aklan.

The respondents presented evidence of their possession and inheritance of the land, which was later occupied and converted into a fishpond by the ANCF. The MCTC rendered a decision in favor of the respondents, declaring them as the owners and possessors of the land and ordering the segregation of the land from the ANCF reservation. The MCTC also awarded damages and attorney's fees to the respondents.

The petitioner, represented by the ANCF and its Superintendent, appealed the MCTC decision to the Regional Trial Court (RTC), which affirmed the decision with modification absolving one of the appellants from the payment of damages and attorney's fees. The RTC emphasized that Proclamation No. 2074 recognizes vested rights acquired by private individuals prior to its issuance.

The petitioner then filed a Petition for Review with the Court of Appeals (CA). The CA dismissed the petition, stating that the subject land could be deemed privately possessed for over 30 years before its declaration as a timberland. The petitioner filed a Petition for Review arguing that the CA gravely erred in upholding the respondents' claim of private rights over the land and in affirming the decisions of the RTC and MCTC releasing the land from the public domain and awarding damages to the respondents.

ISSUES:

  1. Whether respondents retain private rights to the disputed property, preventing the application of Proclamation No. 2074

  2. Whether respondents complied with the requirements for judicial confirmation of imperfect title

  3. Whether or not the land subject of the application for registration is alienable or disposable.

  4. Whether or not there exists a positive act of the government declaring the land as alienable and disposable.

  5. Whether unclassified lands are considered inalienable public lands.

  6. Whether lands declared alienable or disposable after June 12, 1945 may be subject to judicial confirmation of imperfect title.

  7. Whether the respondents have identified a positive act of the government declassifying the subject land.

RULING:

  1. The Court of Appeals erred in affirming the lower courts' decision that respondents retain private rights to the disputed property. The disputed property was classified as timberland before its formal classification as such in 1960 and therefore remains part of the inalienable public domain.

  2. Respondents failed to comply with the requirements for judicial confirmation of imperfect title. They did not file an application for judicial confirmation of imperfect title and did not establish open, continuous, exclusive, and notorious possession and occupation under a bona fide claim of ownership since June 12, 1945, or earlier.

  3. The burden of proof is on the person applying for registration to prove that the land subject of the application is alienable or disposable. Incontrovertible evidence must be established to overcome the presumption of State ownership of the lands of the public domain.

  4. To prove that the land subject of an application for registration is alienable, the applicant must establish the existence of a positive act of the government, such as a presidential proclamation or an executive order; an administrative action; investigation reports of Bureau of Lands investigators; and a legislative act or a statute. The applicant may also secure a certification from the government that the land claimed to have been possessed for the required number of years is alienable and disposable.

  5. Yes, according to Heirs of the Late Spouses Pedro S. Palanca and Soterranea Rafols v. Republic, the presumption is that unclassified lands are inalienable public lands.

  6. The members of the Court were divided on whether lands declared alienable or disposable after June 12, 1945 may be subject to judicial confirmation of imperfect title, but it was agreed that there must be a declaration to that effect.

  7. Since the respondents failed to identify a positive act of the government declassifying the subject land, their alleged possession and that of their predecessors-in-interest is inconsequential and could never ripen into ownership.

PRINCIPLES:

  • Under the Regalian Doctrine, all lands of the public domain belong to the State, unless reclassified or released as alienable agricultural land or alienated to a private person by the State.

  • Public lands not shown to have been reclassified or released as alienable agricultural land or alienated to a private person remain part of the inalienable public domain.

  • Two requisites for judicial confirmation of imperfect or incomplete title are: (1) open, continuous, exclusive, and notorious possession and occupation of the subject land under a bona fide claim of ownership since time immemorial or from June 12, 1945; and (2) the classification of the land as alienable and disposable land of the public domain.

  • Property of the public domain is beyond the commerce of man and not susceptible of private appropriation and acquisitive prescription.

  • Unclassified lands are considered inalienable public lands, and the burden of proof lies on the person claiming ownership to establish that the land is alienable or disposable.

  • There must be a positive act of the government declaring land as alienable and disposable, which may be proven through various means such as proclamations, executive orders, administrative actions, reports, statutes, or certifications.

  • Unclassified lands are presumed to be inalienable public lands.

  • Lands must be declared alienable or disposable for them to be subject to judicial confirmation of imperfect title.

  • The burden of proving the positive act of the government declassifying land lies on the claimant.