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HEIRS OF ZOSIMO Q. MARAVILLA v. PRIVALDO TUPAS

FACTS:

The case involves a dispute over a parcel of land in Barangay Balabag, Malay, Aklan. The respondent, Zosimo Maravilla, claimed ownership over a 10,000 square meter portion of the property based on a Deed of Sale. Maravilla filed a case for quieting of title and recovery of possession before the RTC, which declared the Deed of Sale as valid and awarded Maravilla one-half portion of the property. Maravilla appealed to the CA, which declared Maravilla the owner of a 10,000 square meter undivided share and ordered the partition of the land. Maravilla then filed a case for partition and damages before another branch of the RTC, which declared a one-hectare portion as Maravilla's rightful share. The CA dismissed Maravilla's appeal, citing res judicata. Maravilla filed a motion for execution of the March 31, 2003 decision before the RTC.

The case involves a dispute over a tract of land on Boracay Island. The heirs of Maravilla claim ownership of a portion of the land based on a Deed of Sale of Unregistered Land. The RTC granted a motion for execution, but the CA set aside the said orders, declaring them null and void. The heirs of Maravilla filed a petition for review, arguing that the CA's decision was erroneous and that they were entitled to the execution of the judgments that have become final and executory.

The case involves a dispute over land ownership in Boracay Island. Respondents-claimants filed a petition for declaratory relief, claiming that Proclamation No. 1801 and PTA Circular No. 3-82 raised doubts on their right to secure titles over their occupied lands. The Republic opposed the petition, arguing that Boracay Island was an unclassified land of the public domain. The RTC took judicial notice that certain parcels of land in Boracay Island were involved in other civil cases.

ISSUES:

  1. Whether or not private individuals may acquire vested right of ownership over the island of Boracay.

  2. Whether private individuals may acquire vested right of ownership over Boracay Island.

  3. Whether Proclamation No. 1801 converted Boracay Island into an agricultural land.

  4. Whether Proclamation No. 1801 made Boracay Island alienable and disposable.

  5. Whether Proclamation No. 1064 effectively classified parts of Boracay Island as alienable and open to private ownership.

  6. Whether the sale of an unregistered land, declared forest land, is valid and enforceable.

RULING:

  1. The Supreme Court held that private individuals cannot acquire vested right of ownership over the island of Boracay. The Court ruled that Boracay is an unclassified public forest land which is inalienable and cannot be the subject of judicial confirmation of imperfect title. Only the executive department has the authority to reclassify lands of the public domain into alienable and disposable lands.

  2. Private individuals cannot acquire vested right of ownership over Boracay Island. Boracay Island is considered a public land, specifically a forest land, according to the classification under PD No. 705. The classification of Boracay Island as a forest land is not negated by the fact that it has been developed for commercial purposes or that it no longer has forest cover. Until officially released from its classification as forest land, it remains part of the public domain and cannot be the subject of private ownership.

  3. Proclamation No. 1801 did not convert Boracay Island into an agricultural land. The proclamation classified Boracay Island, among other islands, as a tourist zone but did not specifically declare it as an agricultural land. The reference to "private lands" and "areas declared as alienable and disposable" in Circular No. 3-82, which implements Proclamation No. 1801, does not automatically classify the entire island as agricultural. The proclamation and circular recognized that the classification of the island as alienable and disposable land can only be done by the executive department in accordance with its powers under CA No. 141.

  4. Proclamation No. 1801 did not make Boracay Island alienable and disposable. The proclamation aimed to administer the island for tourism and ecological purposes, but it did not address the island's alienability. Therefore, it did not open the island to private ownership.

  5. Proclamation No. 1064 effectively classified parts of Boracay Island as alienable and open to private ownership. President Gloria Macapagal-Arroyo had the authority to classify lands of the public domain, and in issuing the proclamation, she exercised that authority subject to existing vested rights.

  6. The sale of unregistered land that is declared forest land is null and void. Only things not outside the commerce of man may be the object of contracts, and contracts whose objects are outside the commerce of man are non-existent and void ab initio, as provided in Articles 1347 and 1409 of the Civil Code. The decision in The Secretary of the Department of Environment and Natural Resources (DENR), et al. v. Yap, et al. and Sacay, et al. v. the Secretary of the DENR, et al. is considered a supervening event that can stay the execution of a final and immutable judgment. A supervening event must directly affect the matter litigated and settled, or substantially change the rights or relations of the parties, rendering the execution unjust, impossible, or inequitable. The party claiming a supervening event must prove the facts by competent evidence, otherwise it would frustrate the conclusive effects of a final and immutable judgment.

PRINCIPLES:

  • Lands classified as "public forest" are inalienable and cannot be subject to judicial confirmation of imperfect title.

  • Only the executive department has the authority to reclassify lands of the public domain into alienable and disposable lands.

  • Boracay Island is classified as a public land, specifically a forest land, until officially released from its classification. The physical appearance or development of the land does not change its legal status.

  • Proclamation No. 1801 did not convert the entire Boracay Island into an agricultural land. The proclamation and its implementing circular recognized the authority of the executive department to classify specific areas of the island as alienable and disposable.

  • Classification of public lands is the exclusive prerogative of the Executive Department, through the Office of the President. Courts have no authority to do so.

  • All lands of the public domain belong to the State, and the State has the power to determine if and how these lands will be disposed of or conveyed to private individuals.

  • Lands that have not been acquired from the government belong to the State as part of the inalienable public domain.

  • Possession of public lands, no matter how long, cannot confer ownership or possessory right when the land is not alienable and disposable.

  • A claimant cannot acquire a greater right than what their predecessor-in-interest had, especially when the basis of the predecessor-in-interest's claim is no longer tenable.

  • Only things not outside the commerce of man may be the object of contracts (Article 1347, Civil Code).

  • Contracts whose objects are outside the commerce of man are non-existent and void ab initio (Article 1409, Civil Code).

  • A supervening event may stay the execution of a final and immutable judgment if it directly affects the matter litigated and settled, or substantially changes the rights or relations of the parties, rendering the execution unjust, impossible, or inequitable.

  • The party claiming a supervening event must prove the facts by competent evidence, otherwise it would frustrate the conclusive effects of a final and immutable judgment.