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Villarico V CA

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Bernadette Sandoval

The Supreme Court held that private persons cannot own forest lands, and possession of forest lands, no matter how long, does not ripen into a registrable title. The applicants sought confirmation of title over land in Meycauayan, Bulacan, claiming they bought the land and had possessed it for over 30 years. However, the government opposed registration, stating the land was part of the public domain and unclassified forest area. Since the land was not declared disposable by the Director of Forestry, it remained forest land that could not be privately owned through possession alone.

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Villarico V CA

Uploaded by

Bernadette Sandoval
80 views1 page
The Supreme Court held that private persons cannot own forest lands, and possession of forest lands, no matter how long, does not ripen into a registrable title. The applicants sought confirmation of title over land in Meycauayan, Bulacan, claiming they bought the land and had possessed it for over 30 years. However, the government opposed registration, stating the land was part of the public domain and unclassified forest area. Since the land was not declared disposable by the Director of Forestry, it remained forest land that could not be privately owned through possession alone.

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Villarico v CA

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The Supreme Court held that private persons cannot own forest lands, and possession of forest lands, no matter how long, does not ripen into a registrable title. The applicants sought confirmation of title over land in Meycauayan, Bulacan, claiming they bought the land and had possessed it for over 30 years. However, the government opposed registration, stating the land was part of the public domain and unclassified forest area. Since the land was not declared disposable by the Director of Forestry, it remained forest land that could not be privately owned through possession alone.

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© All Rights Reserved
Download as DOCX, PDF, TXT or read online from Scribd
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80 views1 page

Villarico V CA

Uploaded by

Bernadette Sandoval
The Supreme Court held that private persons cannot own forest lands, and possession of forest lands, no matter how long, does not ripen into a registrable title. The applicants sought confirmation of title over land in Meycauayan, Bulacan, claiming they bought the land and had possessed it for over 30 years. However, the government opposed registration, stating the land was part of the public domain and unclassified forest area. Since the land was not declared disposable by the Director of Forestry, it remained forest land that could not be privately owned through possession alone.

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G.R. No.

132115 The trial court dismissed the case saying that “a certificate of
title is void when it covers property of the public domain
January 4, 2002 classified as forest or timber and mineral lands. Any title thus
TEOFILO C. VILLARICO, Petitioner, v. issued on non-disposable lots, even in the hands of an innocent
purchaser for value, should be cancelled.”
COURT OF APPEALS, DIOSDADO AZARRAGA and
LOLITA ACEBO AZARRAGA, respondents. ISSUE:

Ponente: QUISUMBING, J.: Whether or not the property in question can be registered by
the applicant or by the oppositor or by their respective
DOCTRINE: predecessors-in-interest?

Private persons cannot own forest lands. Possession thereof, no HELD:


matter how long, does not ripen into a registrable title.
The Supreme Court Held in the negative. Since there is
FACTS: no showing that a declassification has been made by the
Director of Forestry declaring the land in question as
Spouses Villarico filed an application for confirmation
disposable or alienable, the land remains to be part of the
of title over a parcel of land in Meycauayan, Bulacan. The
public domain as a forest land. Considering this, possession of
applicants alleged that 1)they are the absolute owners of the
the land in question by the applicants and/or their predecessors-
property having bought the same from Segundo Villarico and
in-interest even for more than 30 years does not convert the
Mercedes Cardenas, 2) they and their predecessors-in-interest
land into private property capable of private appropriation.
have been in actual, open, adverse and continuous possession
thereof for more than 30 years, 3) they are not aware of any NOTES/RATIO:
mortgage or encumbrance thereon nor of any person having an
estate or interest therein, and 4) the land involved is not within The SC stated that forest lands cannot be owned by private
the forest zone or government reservation. persons. Its possession, no matter how long it is, does not ripen
into a registrable title. Furthermore, it must be noted that the
Marcos Camargo opposed the application for the registration of adverse possession which may be the basis of a grant of title or
the land claiming that he is the real owner thereof. The confirmation of an imperfect title refers only to alienable or
Government interposed its opposition, through the Director of disposable portions of the public domain.
Forestry, averring that the land in question is part of the public
domain, within the unclassified area in Meycauayan, Bulacan
hence, it is not available for private appropriation.

DIGEST AUTHOR: Sandoval, B.C.

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