Ferdinand Sicoy 26 January 2018

JDCVL204
Land Title and Deeds

CASE DIGEST
Republic of the Philippines, petitioner
versus
Celestina Naguiat, respondent
G.R. No. 134209. January 24, 2006

Facts:

Celestina Naguiat, an Filipino citizen, resident of Angeles City Pampanga, applied

for registration before the Regional Trial Court of Zambales, four parcels of land located
in Panan, Botolan Zambales.

She alleges to be the owner of the said parcels of land having acquired them by
purchase from an entity who have been in possession thereof for more than thirty (30)
years that had not suffered from any mortgage or encumbrance of whatever kind nor is
there any person having any interest, legal or equitable, or in possession thereof.

The Republic of the Philippines filed an opposition to the application assailing the
ownership of the respondent on the grounds of open, continuous, exclusive and
notorious possession and occupation of the lands in question by the predecessors-in-
interest that is an ownership in fee simple on the basis of Spanish title or grant that is
no longer applicable; the subject properties are part of the public domain belonging to
the Republic of the Philippines not subject to private appropriation.

The trial court adjudicated the land to the respondent and affirmed by the
appellate court, hence the petition for review.

Issue:

Whether the areas in question still part of public domain?

Ruling:

The Court ruled that the areas are still part of the public domain. The respondent
failed to present the required certification from the proper government agency or
proclamation reclassifying the land applied for as alienable and disposable.

Under Section 2, Article XII of the Constitution, under the Regalian doctrine, all
lands of the public domain belongs to the State. Accordingly public lands not shown to
have been reclassified or released as alienable agricultural land or alienated to a private
person by the State remain part of the inalienable public domain.

Anent thereto, under the Section 6 of the Public Land Act, the prerogative of
classifying and reclassifying lands of the public domain belongs to the Executive Branch
and not with the court. The lower court and the appellate court erred in deciding in
favor of the respondent with subsisting matters that rest in the powers of the Executive
Branch of government.

Unclassified land cannot be acquired by adverse occupation or possession unless

until determined by the proper government agency or proclamation reclassifying the
land agricultural thus alienable and disposable. The Court properly REVERSED and SET
ASIDE the decisions of the lower court and appellate court and the application of the
respondent DENIED.