1. LEUNG YEE, plaintiff-appellant, vs. FRANK L. STRONG MACHINERY COMPANY and J. G.

WILLIAMSON, defendants-appellees.

FACTS: The "Compañia Agricola Filipina" bought rice-cleaning machineries from Strong
Machinery (machinery company). It executed a chattel mortgage over the machineries as well as
the building in which the machinery was installed, without any reference to the land on which it
stood. Upon failure to pay, the registered mortgage was foreclosed, and the building was
purchased by Strong Machinery. The mortgage was registered in the chattel mortgage registry,
and the sale of the property to Strong Machinery was annotated in the same registry.

A few weeks thereafter, the "Compañia Agricola Filipina" executed a deed of sale of the land upon
which the building stood to Strong Machinery, but this deed of sale, although executed in a public
document, was not registered. This deed makes no reference to the building erected on the land
and would appear to have been executed for the purpose of curing any defects which might
be found to exist in the Strong Machinery’s title to the building under the sheriff's certificate of
sale. Strong Machinery thereafter took possession of the building.

However, at the time when the chattel mortgage was executed in favor of the Strong Machinery, the
mortgagor, the "Compañia Agricola Filipina" executed another mortgage to the Leung Yee
(plaintiff) upon the building to secure payment of the balance of its indebtedness to Leung
Yee for its construction. For failure to pay, the building was levied and Strong Machinery set up its
claim. Hence, Leung Yee, upon demand, executed an indemnity bond and he was later able to
buy the property during the sheriff’s sale. The sale in favor of Leung Yee was recorded in the
Registry. Leung Yee now sues to recover the property from Strong Machinery.

RTC: relying upon the terms of article 1473 of the Civil Code, gave judgment in favor of the Strong
Machinery, on the ground that the company had its title to the building registered prior to the
date of registry of the plaintiff's certificate. Article 1473: If the same thing should have been sold
to different vendees, the ownership shall be transfer to the person who may have the first taken
possession thereof in good faith, if it should be personal property. Should it be real property, it
shall belong to the person acquiring it who first recorded it in the registry. Should there be no
entry, the property shall belong to the person who first took possession of it in good faith, and, in
the absence thereof, to the person who presents the oldest title, provided there is good faith.

ISSUE: Who has a better right to the property? STRONG MACHINERY.

RULING: The registry here referred to in Article 1473 is of course the registry of real property, and it
must be apparent that the annotation or inscription of a deed of sale of real property in a chattel
mortgage registry cannot be given the legal effect of an inscription in the registry of real
property. The building of strong materials in which the rice-cleaning machinery was installed by the
"Compañia Agricola Filipina" was real property, and the mere fact that the parties seem to have
dealt with it separate and apart from the land on which it stood in no wise changed its
character as real property. It follows that neither the original registry in the chattel mortgage of the
building and the machinery installed therein, not the annotation in that registry of the sale of the
mortgaged property, had any effect whatever so far as the building was concerned.

The judgment must be sustained on the ground that neither the purchase of the building by the
plaintiff nor his inscription of the sheriff's certificate of sale in his favor was made in good
faith, and that the machinery company must be held to be the owner of the property under the third
part of the above cited article, it appearing that the company first took possession of the property; and
further, that the building and the land were sold to the machinery company long prior to the date of
the sheriff's sale to the plaintiff.

It has been suggested that since the provisions of article 1473 of the Civil Code require "good faith,"
in express terms, in relation to "possession" and "title," but contain no express requirement as to
"good faith" in relation to the "inscription" of the property on the registry, it must be presumed that
good faith is not an essential requisite of registration in order that it may have the effect contemplated
in this article. We cannot agree with this contention. It could not have been the intention of the
legislator to base the preferential right secured under this article of the code upon an inscription of
title in bad faith. Such an interpretation placed upon the language of this section would open wide the
door to fraud and collusion.

The plaintiff, when he bought the building at the sheriff's sale and inscribed his title in the land
registry, was duly notified that the machinery company had bought the building from
plaintiff's judgment debtor; that it had gone into possession long prior to the sheriff's sale; and
that it was in possession at the time when the sheriff executed his levy. The execution of an
indemnity bond by the plaintiff in favor of the sheriff, after the machinery company had filed its sworn
claim of ownership, leaves no room for doubt in this regard. Having bought in the building at the
sheriff's sale with full knowledge that at the time of the levy and sale the building had already
been sold to the machinery company by the judgment debtor, the plaintiff cannot be said to have
been a purchaser in good faith; and of course, the subsequent inscription of the sheriff's certificate of
title must be held to have been tainted with the same defect.

One who purchases real estate with knowledge of a defect or lack of title in his vendor cannot
claim that he has acquired title thereto in good faith as against the true owner of the land or of
an interest therein; and the same rule must be applied to one who has knowledge of facts which
should have put him upon such inquiry and investigation as might be necessary to acquaint
him with the defects in the title of his vendor. A purchaser cannot close his eyes to facts which
should put a reasonable man upon his guard, and then claim that he acted in good faith under the
belief that there was no defect in the title of the vendor.

2. DEVELOPMENT BANK OF THE PHILIPPINES, petitioner, vs. COURT OF APPEALS, MYLO O.

QUINTO and JESUSA CHRISTINE S. CHUPUICO, respondents.

FACTS: Petitioner bank DBP granted a loan of P94,000 to the spouses Olidiana. To secure the loan,
the Olidiana spouses executed a REM on several properties among which was Lot 2029 in
Zamboanga del Sur. At the time of the mortgage, the property was still the subject of a Free Patent
application filed by the Olidianas with the Bureau of Lands but registered under their name in
the Office of the Municipal Assessor for taxation purposes. Later, the Olidiana spouses filed with
the Bureau of Lands a Request for Amendment of their Free Patent applications over several
parcels of land including Lot No. 2029. They renounced, relinquished and waived all their
rights and interests over it in favor of Chupuico and Quinto, respondents herein. Free Patents
were granted to Chupuico and Quinto and they obtained an OCT.

A year later, an additional loan of P62,000 was extended by petitioner bank to the Olidiana spouses.
Thus the Olidianas executed an additional mortgage on the same parcels of land already
covered by the first mortgage. This second mortgage also included Lot No. 2029. For spouses
Olidiana’s failure to pay, petitioner bank extrajudicially foreclosed all their mortgaged properties.
These properties including Lot No. 2029 were sold at public auction and awarded to petitioner bank
as the highest bidder. However, when petitioner tried to register the sale and the affidavit of
consolidation, it was discovered that Lot No. 2029 had already been divided into 2 parcels,
and registered under the names of Chupuico and Quinto. In view of the discovery, petitioner bank
filed an action for Quieting of Title and Cancellation or Annulment of Certificate of Title against
respondents.

RTC: ruled against petitioner bank. It ruled that the contracts of mortgage could not have vested valid
title to petitioner bank because the mortgagors were not the owners in fee simple of the
property mortgaged. It also said that with the subsequent issuance of the Free Patent by the Bureau
of Lands in the name of respondents Chupuico and Quinto, it could be gleaned that the property was
indeed public land when mortgaged to petitioner. Therefore petitioner could not have acquired
a valid title over the subject property by virtue of the foreclosure and subsequent sale at
public auction. CA: affirmed

ISSUE: WON the land in dispute could have been validly mortgaged while still the subject of a Free
Patent Application with the government?

HELD: NO. We hold that petitioner bank did not acquire valid title over the land in dispute
because it was public land when mortgaged to the bank. We cannot accept petitioner's
contention that the lot in dispute was no longer public land when mortgaged to it since the
Olidiana spouses had been in open, continuous, adverse and public possession thereof for
more than 30 years. In Visayan Realty, Inc. v. Meer we ruled that the approval of a sales
application merely authorized the applicant to take possession of the land so that he could
comply with the requirements prescribed by law before a final patent could be issued in his
favor. Meanwhile the government still remained the owner thereof, as in fact the application could still
be canceled and the land awarded to another applicant should it be shown that the legal
requirements had not been complied with. What divests the government of title to the land is the
issuance of the sales patent and its subsequent registration with the Register of Deeds. It is
the registration and issuance of the certificate of title that segregate public lands from the mass of
public domain and convert it into private property. Since the disputed lot in the case before us was
still the subject of a Free Patent Application when mortgaged to petitioner and no patent was granted
to the Olidiana spouses, Lot No. 2029 remained part of the public domain.

With regard to the validity of the mortgage contracts entered into by the parties, Art. 2085, par. 2, of
the New Civil Code specifically requires that the pledgor or mortgagor be the absolute owner of
the thing pledged or mortgaged. Thus, since the disputed property was not owned by the
Olidiana spouses when they mortgaged it to petitioner the contracts of mortgage and all their
subsequent legal consequences as regards Lot No. 2029 are null and void. Also, as correctly
found by the lower courts, no evidence existed to show that respondents had prior knowledge of
the real estate mortgages executed by the Olidiana spouses in favor of petitioner. The act of
respondents in securing the patents cannot therefore be categorized as having been tainted
with fraud.
HEIRS OF LEOPOLDO DELFIN AND SOLEDAD DELFIN, NAMELY EMELITA D. FABRIGAR AND
LEONILO C. DELFIN, Petitioners, v. NATIONAL HOUSING AUTHORITY, Respondent. (Leonen
case)

FACTS: In a Complaint for "Payment of Parcel(s) of Land and Improvements and Damages" the
Delfin Spouses claimed that they were the owners of a 28,800 square meter parcel of land in
Iligan City ("Iligan Property"). They allegedly bought the property in 1951 from Natingo and
Carbonay, who, allegedly, had been in actual possession of the property since time
immemorial. The Delfin Spouses had been declaring the Iligan Property in their names for tax
purposes since 1952, and had been planting it with fruits and crops. They alleged that sometime
in 1982, respondent NHA forcibly took possession of a 10,798 square meter portion of the
property. Despite their repeated demands for compensation, the NHA failed to pay the value of
the property.

In its Answer, the NHA alleged that the Delfin Spouses' property was part of a military reservation
area. It cited Proclamation No. 2143 as having supposedly reserved the area in which property is
situated for Iligan City's slum improvement and resettlement program, and the relocation of
families who were dislocated by the National Steel Corporation's five-year expansion program.
Proclamation No. 2151 also mandated it to determine the improvements' valuation. It emphasized
that among all claimants, only the Delfin Spouses and two others remained unpaid because of
their disagreement on the property's valuation. RTC: rendered a Decision in favor of the Delfin
Spouses. CA: reversed.

ISSUE: WON petitioners are entitled to just compensation for the Iligan City property occupied by
respondent NHA? YES.

I. Petitioners are erroneously claiming title based on acquisitive prescription under Section
14(2) of Presidential Decree No. 1529.

Section 14 reads in full: The following persons may file in the proper CFI an application for
registration of title to land, whether personally or through their duly authorized representatives:
(1) Those who by themselves or through their predecessors-in-interest have been in open,
continuous, exclusive and notorious possession and occupation of alienable and disposable
lands of the public domain under a bona fide claim of ownership since June 12, 1945, or earlier; (2)
Those who have acquired ownership of private lands by prescription under the provision of
existing laws; (3) Those who have acquired ownership of private lands or abandoned river beds by
right of accession or accretion under the existing laws; and (4)Those who have acquired ownership
of land in any other manner provided for by law.

Property - such as land - is either of public dominion or private ownership. Only publicly owned lands
which are patrimonial in character are susceptible to prescription under Section 14(2) of PD
1529. Consistent with this, Article 1113 of Civil Code demarcates properties of the state, which are
not patrimonial in character, as being not susceptible to prescription. Contrary to petitioners'
theory then, for prescription to be viable, the publicly-owned land must be patrimonial or private in
character at the onset. Possession for thirty (30) years does not convert it into patrimonial
property. For land of the public domain to be converted into patrimonial property, there must
be an express declaration - "in the form of a law duly enacted by Congress or a Presidential
Proclamation in cases where the President is duly authorized by law" - that "the public dominion
property is no longer intended for public service or the development of the national wealth or that the
property has been converted into patrimonial.”

Heirs of Malabanan v. Republic explains: For as long as the property belongs to the State, although
already classified as alienable or disposable, it remains property of the public dominion if when *
it is "intended for some public service or for the development of the national wealth".

Accordingly, there must be an express declaration by the State that the public dominion property is
no longer intended for public service or the development of the national wealth or that the
property has been converted into patrimonial. Without such express declaration, the property,
even if classified as alienable or disposable, remains property of the public dominion, pursuant to
Article 420 (2), and thus incapable of acquisition by prescription. It is only when such alienable and
disposable lands are expressly declared by the State to be no longer intended for public service
or for the development of the national wealth that the period of acquisitive prescription can
begin to run. Such declaration shall be in the form of a law duly enacted by Congress or a
Presidential Proclamation in cases where the President is duly authorized by law.
Attached to the present Petition was a copy of a May 18, 1988 supplemental letter to the Director of
the Land Management Bureau. This referred to an executive order indorsed by the executive
secretary, which stated that petitioners' property was no longer needed for any public or quasi-
public purposes. However, a mere indorsement of the executive secretary is not the law or
presidential proclamation required for converting land of the public domain into patrimonial
property and rendering it susceptible to prescription. There then was no viable declaration
rendering the Iligan property to have been patrimonial property at the onset. Accordingly, regardless
of the length of petitioners' possession, no title could vest on them by way of prescription.

II. While petitioners may not claim title by prescription, they may, nevertheless, claim title
pursuant to Section 48 (b) of Commonwealth Act No. 141 (the Public Land Act).

Section 48(b) of the Public Land Act requires that 2 requisites be satisfied before claims of title to
public domain lands may be confirmed: first, that the land subject of the claim is agricultural land;
and second, open, continuous, notorious, and exclusive possession of the land since June 12,
1945.

The need for the land subject of the claim to have been classified as agricultural is in conformity with
the constitutional precept that "[a]lienable lands of the public domain shall be limited to agricultural
lands." As explained in Heirs of Malabanan v. Republic: Whether or not land of the public domain is
alienable and disposable primarily rests on the classification of public lands made under the
Constitution. The 1987 Constitution adopted the classification under the 1935 Constitution into
agricultural, forest or timber, and mineral, but added national parks. The identification of lands
according to their legal classification is done exclusively by and through a positive act of the
Executive Department.

Based on the foregoing, the Constitution places a limit on the type of public land that may be
alienated. Under Section 2, Article XII of the 1987 Constitution, only agricultural lands of the public
domain may be alienated; all other natural resources may not be.

Alienable and disposable lands of the State fall into two categories, to wit: (a) patrimonial lands of
the State, or those classified as lands of private ownership under Article 425 of the Civil Code,
without limitation; and (b) lands of the public domain, or the public lands as provided by the
Constitution, but with the limitation that the lands must only be agricultural. Consequently,
lands classified as forest or timber, mineral, or national parks are not susceptible of alienation
or disposition unless they are reclassified as agricultural. A positive act of the Government is
necessary to enable such reclassification, and the exclusive prerogative to classify public lands under
existing laws is vested in the Executive Department, not in the courts.

That the Iligan property was alienable and disposable, agricultural land, has been admitted. What is
claimed instead is that petitioners' possession is debunked by how the Iligan Property was
supposedly part of a military reservation area which was subsequently reserved for Iligan City's slum
improvement and resettlement program, and the relocation of families who were dislocated by the
National Steel Corporation's five-year expansion program.

Indeed, by virtue of Proclamation No. 2143 parcels of land in Barrio Suarez, Iligan City were reserved
for slum-improvement and resettlement program purposes. The proclamation characterized the
covered area as "disposable parcel of public land.” However, it also states that: “This
Proclamation is subject to the condition that the qualified free patent applicants occupying
portions of the aforedescribed parcel of land, if any, may be compensated for the value of
their respective portions and existing improvements thereon, as may be determined by the
NHA.” Whatever rights petitioners (and their predecessors-in-interest) may have had over the Iligan
property was, thus, not obliterated by Proclamation No. 2143. On the contrary, the Proclamation
itself facilitated compensation.

First, there is no issue that the Iligan Property had already been declared to be alienable and
disposable land. Respondent has admitted this and Deputy Public Land Inspector Pio Lucero, Jr.'s
letters to the Director of Land attest to this. Second, although the Delfin Spouses' testimonial
evidence and tax declarations showed that their possession went only as far back as 1952,
Deputy Public Land Inspector Pio Lucero, Jr.'s letters to the Director of Land nevertheless
attest to a previous finding that the property had already been occupied as early as June 1945.
Having shown that the requisites of Section 48(b) of the Public Land Act have been satisfied and
having established their rights to the Iligan Property, it follows that petitioners must be compensated
for its taking.

HEIRS OF MARIO MALABANAN, (Represented by Sally A. Malabanan) vs. REPUBLIC OF THE

PHILIPPINES
FACTS: The property subject of the application for registration is a parcel of land situated in
Cavite. On February 20, 1998, applicant Mario Malabanan, who had purchased the property
from Velazco, filed an application for land registration covering the property in the RTC
claiming that the property formed part of the alienable and disposable land of the public domain,
and that he and his predecessors-in-interest had been in open, continuous, uninterrupted, public
and adverse possession and occupation of the land for more than 30 years, thereby entitling
him to the judicial confirmation of his title. To prove that the property was an alienable and
disposable land of the public domain, Malabanan presented during trial a certification dated June 11,
2001 issued by the Community Environment and Natural Resources Office (CENRO) of the
DENR.

RTC: granted the application. CA: reversed. It declared that under Section 14(1) of the Property
Registration Decree, any period of possession prior to the classification of the land as alienable
and disposable was inconsequential and should be excluded from the computation of the
period of possession. Noting that the CENRO-DENR certification stated that the property had been
declared alienable and disposable only on March 15, 1982, Velazco’s possession prior to March
15, 1982 could not be tacked for purposes of computing Malabanan’s period of possession.
SC: denied the petition for Malabanan’s failure to establish possession and occupation of the property
on his part and on the part of his predecessors-in interest since June 12, 1945, or earlier. Hence, this
MR.

ISSUES:

1. What are the classifications of public lands?

2. Whether or not petitioners were able to prove that the property was an alienable and disposable
land of the public domain.

HELD:

1. Classifications of land according to ownership: Land may be classified as either of public

dominion or of private ownership. Land is considered of public dominion if it either: (a) is intended
for public use; or (b) belongs to the State, without being for public use, and is intended for some
public service or for the development of the national wealth. Land belonging to the State that is not of
such character, or although of such character but no longer intended for public use or for public
service forms part of the patrimonial property of the State. Land that is other than part of the
patrimonial property of the State, provinces, cities and municipalities is of private ownership if it
belongs to a private individual.

Classifications of public lands according to alienability: It primarily rests on the classification of

public lands made under the Constitution. 1935 Constitution: agricultural, timber and mineral. 1973
Constitution: agricultural, industrial or commercial, residential, resettlement, mineral, timber or forest,
and grazing land, with the reservation that the law might provide other classifications. 1987
Constitution: adopted the classification under the 1935 Constitution into agricultural, forest or
timber, and mineral, but added national parks. Agricultural lands may be further classified by law
according to the uses to which they may be devoted. The identification of lands according to their
legal classification is done exclusively by and through a positive act of the Executive
Department. Under Section 2, Article XII of the 1987 Constitution, only agricultural lands of the
public domain may be alienated; all other natural resources may not be.

Alienable and disposable lands of the State fall into two categories, to wit: (a) patrimonial lands of
the State, and (b) lands of the public domain, or the public lands as provided by the
Constitution, but with the limitation that the lands must only be agricultural. Consequently,
lands classified as forest or timber, mineral, or national parks are not susceptible of alienation or
disposition unless they are reclassified as agricultural. A positive act of the Government is
necessary to enable such reclassification, and the exclusive prerogative to classify public lands under
existing laws is vested in the Executive Department, not in the courts. If, however, public land will be
classified as neither agricultural, forest or timber, mineral or national park, or when public
land is no longer intended for public service or for the development of the national wealth,
thereby effectively removing the land from the ambit of public dominion, a declaration of such
conversion must be made in the form of a law duly enacted by Congress or by a Presidential
proclamation in cases where the President is duly authorized by law to that effect. Thus, until
the Executive Department exercises its prerogative to classify or reclassify lands, or until Congress or
the President declares that the State no longer intends the land to be used for public service or
for the development of national wealth, the Regalian Doctrine is applicable.

2. Section 48(b) of the Public Land Act, Section 48 states: The following citizens of the Philippines,
occupying lands of the public domain or claiming to own any such lands or an interest therein, but
whose titles have not been perfected or completed, may apply to the CFI of the province where
the land is located for confirmation of their claims and the issuance of a certificate of title :xxx
(b) Those who by themselves or through their predecessors-in-interest have been in open,
continuous, exclusive, and notorious possession and occupation of alienable and disposable lands of
the public domain, under a bona fide claim of acquisition of ownership, since June 12, 1945, or
earlier, immediately preceding the filing of the applications for confirmation of title, except when
prevented by war or force majeure. These shall be conclusively presumed to have performed all the
conditions essential to a Government grant and shall be entitled to a certificate of title under the
provisions of this chapter. (Bold emphasis supplied)

It presupposes that the land subject of the application for registration must have been already
classified as agricultural land of the public domain in order for the provision to apply. Thus,
absent proof that the land is already classified as agricultural land of the public domain, the
Regalian Doctrine applies, and overcomes the presumption that the land is alienable and disposable
as laid down in Section 48(b) of the Public Land Act.

An examination of Section 48(b) indicates that Congress prescribed no requirement that the land
subject of the registration should have been classified as agricultural since June 12, 1945, or earlier.
As such, the applicant’s imperfect or incomplete title is derived only from possession and
occupation since June 12, 1945, or earlier. This means that the character of the property
subject of the application as alienable and disposable agricultural land of the public domain
determines its eligibility for land registration, not the ownership or title over it. Alienable public
land held by a possessor, either personally or through his predecessors-in-interest, openly,
continuously and exclusively during the prescribed statutory period is converted to private
property by the mere lapse or completion of the period. In fact, by virtue of this doctrine,
corporations may now acquire lands of the public domain for as long as the lands were already
converted to private ownership, by operation of law, as a result of satisfying the requisite period of
possession prescribed by the Public Land Act. It is for this reason that the property subject of the
application of Malabanan need not be classified as alienable and disposable agricultural land of
the public domain for the entire duration of the requisite period of possession.

To be clear, then, the requirement that the land should have been classified as alienable and
disposable agricultural land at the time of the application for registration is necessary only to
dispute the presumption that the land is inalienable. The declaration that land is alienable and
disposable also serves to determine the point at which prescription may run against the State.
The imperfect or incomplete title being confirmed under Section 48(b) of the Public Land Act is title
that is acquired by reason of the applicant’s possession and occupation of the alienable and
disposable agricultural land of the public domain. Where all the necessary requirements for a
grant by the Government are complied with through actual physical, open, continuous, exclusive
and public possession of an alienable and disposable land of the public domain, the
possessor is deemed to have acquired by operation of law not only a right to a grant, but a
grant by the Government, because it is not necessary that a certificate of title be issued in order
that such a grant be sanctioned by the courts.

To sum up, we now observe the following rules relative to the disposition of public land or lands of the
public domain, namely:

(1) As a general rule and pursuant to the Regalian Doctrine, all lands of the public domain belong
to the State and are inalienable. Lands that are not clearly under private ownership are also
presumed to belong to the State and, therefore, may not be alienated or disposed;

(2) The following are excepted from the general rule, to wit:

(a) Agricultural lands of the public domain are rendered alienable and disposable through any
of the exclusive modes enumerated under Section 11 of the Public Land Act. If the mode is judicial
confirmation of imperfect title under Section 48(b) of the Public Land Act, 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. Thereby, a conclusive presumption that the applicant has performed
all the conditions essential to a government grant arises, and the applicant becomes the owner of
the land by virtue of an imperfect or incomplete title. By legal fiction, the land has already
ceased to be part of the public domain and has become private property.

(b) Lands of the public domain subsequently classified or declared as no longer intended for
public use or for the development of national wealth are removed from the sphere of public
dominion and are considered converted into patrimonial lands or lands of private ownership
that may be alienated or disposed through any of the modes of acquiring ownership under the
Civil Code. If the mode of acquisition is prescription, whether ordinary or extraordinary, proof that
the land has been already converted to private ownership prior to the requisite acquisitive
prescriptive period is a condition sine qua non in observance of the law (Article 1113, Civil
Code) that property of the State not patrimonial in character shall not be the object of prescription.

To reiterate, then, the petitioners failed to present sufficient evidence to establish that they and
their predecessors-in-interest had been in possession of the land since June 12, 1945. Without
satisfying the requisite character and period of possession - possession and occupation that is open,
continuous, exclusive, and notorious since June 12, 1945, or earlier - the land cannot be considered
ipso jure converted to private property even upon the subsequent declaration of it as alienable
and disposable. Prescription never began to run against the State. Likewise, the land continues to
be ineligible for land registration under Section 14(2) of the Property Registration Decree
unless Congress enacts a law or the President issues a proclamation declaring the land as no
longer intended for public service or for the development of the national wealth.