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A.republic v. Naguiat, GR 134209, January 24

The document discusses a land dispute case where a Filipino citizen applied to register four parcels of land but the government opposed it claiming the lands were part of the public domain. The Supreme Court ruled the areas were still part of the public domain as the respondent failed to present required certification from the proper government agency reclassifying the lands.

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Benedicto Pintor
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26 views1 page

A.republic v. Naguiat, GR 134209, January 24

The document discusses a land dispute case where a Filipino citizen applied to register four parcels of land but the government opposed it claiming the lands were part of the public domain. The Supreme Court ruled the areas were still part of the public domain as the respondent failed to present required certification from the proper government agency reclassifying the lands.

Uploaded by

Benedicto Pintor
Copyright
© © All Rights Reserved
We take content rights seriously. If you suspect this is your content, claim it here.
Available Formats
Download as DOCX, PDF, TXT or read online on Scribd
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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Spanish title or grant that is no longer applicable; the subject properties are part of the public domain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 ands 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.

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