Padayao v. Villafuerte, Jr.

Chapter III, Original Registration (P.D. 1529, Sec. 14(1); Civil Code, Arts. 420-422; C.A. No. 141, Sec. 101) — 3.1.A.a.i.1.c, Requisites for Confirmation of Title under Sec. 14(1): Third Requisite (OCEN Possession Under a Bona Fide Claim of Ownership Since June 12, 1945 or Earlier)

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Case DigestWeek 3–4 — The Registries of Deeds and Original Registration

Padayao v. Villafuerte, Jr.

G.R. No. 260415 · January 15, 2025 · Supreme Court — Third Division

Gist

This case is ANALOGOUS to the Topic/Subtopic on the June 12, 1945 possession requisite: it is not a Section 14(1) registration proceeding, but an accion publiciana. Punong Barangay Dante Padayao and his family had long occupied Pitogo Island, Camarines Sur — titled Lot No. 6973 and adjoining untitled Lot No. 6972. In 2009, the Provincial Government forcibly evicted them and demolished their structures, claiming the island was a protected danger zone. The RTC restored Dante's possession of both lots; the CA affirmed only as to titled Lot 6973, reasoning Dante failed to overcome the presumption that untitled Lot 6972 was inalienable public land. The Supreme Court reversed as to Lot 6972: since both lots lie within the same island, evidence of Lot 6973's alienable and disposable character applied equally to Lot 6972, invoking Pasig Rizal Co.'s doctrine that classification as alienable and disposable is itself the "operative act" converting public dominion land into patrimonial property absent prior public use. Because the action was accion publiciana, not a registration proceeding, Dante needed only prove a better right of possession, not ownership — met by his decades of largely uncontested occupation and tax payments.

Core Doctrine

Classification of land as alienable and disposable is itself the operative act converting public dominion property into patrimonial property, requiring no express government declaration where no prior public use is alleged. In an accion publiciana, ownership and title validity are resolved only provisionally, to determine the better right of possession; the claimant need not establish a Section 14(1)-grade chain of title. A party who actively litigates without timely raising a jurisdictional defect apparent on the complaint's face is later estopped from invoking it.

Facts

The Padayaos occupied Pitogo Island since 1920 by Dante's account.
Predecessor Julio obtained a 1934 survey plan and allegedly a free patent, later lost in the 1976 Provincial Capitol fire.
The Municipal Treasurer certified that Mario Padayao paid real property taxes for the island from 1945 to 2009.
On January 6, 2009, the Provincial Government demanded the residents vacate within ten days as a protected danger zone.
Armed men reinforced the threat on January 20, and roughly twenty demolished Dante's and other structures on February 4.
Dante sued for recovery of possession and damages before the RTC on January 20, 2010 — within one year of the demolition.
DENR witness Tengco testified the island was alienable and disposable per Land Classification Map No. 882, certified by the Bureau of Forestry in 1931, and that a PAMB meeting confirmed it was not DENR-protected.
A Katibayan ng Orihinal na Titulo (KOT Blg. 35669) issued in 2010 to the Heirs of Mario for Lot No. 6973, based on a 2008 free-patent application.
Respondents defended the demolition as an exercise of police power over an environmentally threatened area, offering residents financial assistance to relocate voluntarily.
The RTC's April 27, 2018 Decision ordered respondents to vacate and restore both lots to Dante.
The CA's May 25, 2021 Decision affirmed with modification, restoring possession only as to titled Lot 6973, holding Dante failed to prove ownership of untitled Lot 6972, deemed presumptively inalienable.
Both parties' motions for reconsideration were denied, and Dante filed this Rule 45 petition.

Arguments of the Parties

Petitioner. Dante argued Tengco's testimony and the DENR/Bureau of Forestry certifications proved the island alienable and disposable, confirmed by the RTC's own ocular inspection; the 1934 Survey Plan issued to Julio covered both lots; and his possession was interrupted only by the 2009 demolition.

Respondents. Respondents argued Dante failed to prove the island alienable and disposable, since no positive government act of classification independent of Tengco's testimony was shown, and Tengco lacked authority to classify or reclassify public land; absent proof of alienability, no length of possession could ripen into a registrable right.

Common Ground / Stipulations (if any). Both sides treated Lot 6973's status as governed by KOT Blg. 35669; neither disputed the demolition occurred on February 4, 2009, or that Dante's Complaint was filed January 20, 2010.

Issue

MAIN ISSUE (Topic/Subtopic-Centered). Whether evidence establishing Lot No. 6973 as alienable and disposable public land, together with Dante's decades-long, largely uncontested possession corroborated by tax payments dating to 1945, extends to untitled Lot No. 6972, entitling Dante to a better right of possession despite lacking title over it.

SECONDARY ISSUES. Whether the RTC retained jurisdiction over the accion publiciana despite the Complaint's failure to allege the properties' assessed value.

ANCILLARY / INCIDENTAL ISSUES (if any). Whether respondents adequately substantiated that Pitogo Island was validly declared a protected area or danger zone, justifying the 2009 eviction and demolition.

Ruling

On the MAIN ISSUE: YES — both lots lie within Pitogo Island; Land Map 882 and Tengco's uncontroverted testimony established the island's alienable and disposable character, and, per Pasig Rizal Co., such classification is itself "the operative act which converts property of public dominion to patrimonial property," nothing more required absent proof of prior public use. Because the action was accion publiciana, Dante needed only a better right of possession, not title, over Lot 6972 — shown by his uncontested occupation, structures, livestock, tax payments "from 1945 to 2009," and pending free-patent application, effectively admitted in respondents' Answer and testimony. Secondary issue: the RTC's jurisdictional defect in failing to plead assessed value was cured by respondents' failure to timely object; they are estopped from raising it now. Ancillary issue: respondents failed to prove the island was ever validly declared a protected area — no PAMB or DENR issuance was presented, Musa could not identify which agency made the declaration, and the claimed "shoreline" location was contradicted by the sheriff's own ocular measurement of sixty meters from Dante's house. The dispositive portion reads verbatim: "WHEREFORE, the petition is GRANTED. The Decision dated May 25, 2021 and Resolution dated April 22, 2022 of the Court of Appeals in CA-G.R. CV No. 112165 are AFFIRMED with MODIFICATION in that respondents Gov. Luis Raymund F. Villafuerte, Jr., Atty. Janis Ian Regaspi-Cleofe, Jose Franciso L. Musa, Jr., Luis Zulueta, Jovie Villareal, Dondon Obias and the Provincial Government of Camarines Sur... are ORDERED to vacate, turn over, and restore possession of Lot Nos. 6972 and 6973, the latter covered by Katibayan ng Orihinal na Titulo Bilang 35669, to petitioner Punong Barangay Dante Padayao. SO ORDERED."

Ratio

Quoting Pasig Rizal Co., the Court reasoned that "[t]he operative act which converts property of public dominion to patrimonial property is its classification as alienable and disposable land of the public domain, as this classification precisely serves as the manifestation of the State's lack of intent to retain the same for some public use or purpose."
Since Land Map 882 and Tengco's testimony went unrebutted, the Court held "if Land Map 882 and the testimony of Tengco are given credence as to the nature of Lot No. 6973, then it should be the same with Lot No. 6972."
On possession, the Court clarified: "Dante does not seek to obtain title over Lot No. 6972 but only to establish that he has a better right of possession than respondents," his "prior possession... is uncontested and... adequately established," including respondents' own characterization of the demolition as a "relocation of the Pitogo island occupants."
On jurisdiction, the Court held respondents "are estopped from averring it," having "never pointed out the foregoing errors" despite having "actively participated in the case."

Doctrine

Doctrines / Rules / Principles Laid Down.

Classification of land as alienable and disposable is itself the operative act converting public dominion property into patrimonial property, requiring no express government declaration where no prior public use is alleged.
In an accion publiciana, ownership and title validity are resolved only provisionally, to determine the better right of possession; the claimant need not establish a Section 14(1)-grade chain of title.
A party who actively litigates without timely raising a jurisdictional defect apparent on the complaint's face is later estopped from invoking it.

Distinctions / Limitations / Qualifications.

Unlike a Section 14(1) proceeding, which demands affirmative proof of OCEN possession since June 12, 1945 (or the amended statutory period) as a precondition to title, an accion publiciana requires only a better right of possession; the 1945 tax-payment evidence here merely corroborated possession, without triggering Section 14(1) adjudication.

Topic/Subtopic Integration (Mandatory).

ANALOGOUS: the case does not adjudicate a Section 14(1) application, but applies Pasig Rizal Co.'s land-classification doctrine — directly pertinent to the Third Requisite's broader jurisprudential context — and illustrates, by contrast, how much less an accion publiciana claimant must prove regarding possession and land status than a Section 14(1) registration applicant.

Separate Opinions

None. Gaerlan and Dimaampao, JJ., concurred; Caguioa, J., was on official business, and Singh, J., was on leave — no separate opinions were written.

Full Digest — Recitation Format

Full-length digest in the format required by the course digest prompt.

Classification: INCIDENTAL · G.R. No. 260415, January 15, 2025

TOPIC/SUBTOPIC FOCUS: No. 141, the Public Land Act, and P.D. No. 1529, the Property Registration Decree, Republic Act No. 11573, July 16, 2021

I. Gist and Central Doctrine

The relationship of the case of Padayao v. Villafuerte, Jr., G.R. No. 260415, January 15, 2025, to the assigned topic of original land registration under Chapter III, Section 14, paragraph 1 of Presidential Decree No. 1529 is INCIDENTAL but highly persuasive, as the Supreme Court of the Philippines threshes out the land classification status of the properties by directly applying the newly enacted and clarified evidentiary parameters under Section 7 of Republic Act No. 11573 and the landmark En Banc doctrine of Republic v. Pasig Rizal Co., Inc. in the context of an accion publiciana. The triggering controversy arose when the Provincial Government of Camarines Sur forcibly evicted Petitioner Dante Padayao and other residents from Pitogo Island, Caramoan, Camarines Sur, and demolished the residential structures on February 4, 2009 under the unilateral claim that Pitogo Island was a protected area and a danger zone. In response, Petitioner Dante Padayao, representing the Heirs of Mario Padayao, filed a Complaint for recovery of possession (accion publiciana) and damages, asserting prior possession since 1920 and a valid claim of ownership supported by an approved 1934 Survey Plan and subsequent patent title (KOT Blg. 35669). The Supreme Court of the Philippines granted the petition, reversed the partial dismissal by the Court of Appeals, and ordered the full restoration of possession of both Lot Nos. 6972 and 6973 to Petitioner Dante Padayao. The central doctrine established in this case is that while a land registration proceeding is the proper forum to conclusively settle land classification and title under the Torrens system, the land classification status of a parcel of land as alienable and disposable public land may be provisionally determined in an accion publiciana using a land classification map (such as Land Classification Map No. 882) as reliable and sufficient proof pursuant to Section 7 of Republic Act No. 11573 and Republic v. Pasig Rizal Co., Inc., thereby protecting a prior lawful possessor from arbitrary eviction by the State under a baseless invocation of police power.

II. Chronological Narration of Material Facts

In 1920, Petitioner Dante Padayao and the predecessors-in-interest of Petitioner Dante Padayao entered into the actual, open, continuous, and peaceful possession and cultivation of Pitogo Island, Caramoan, Camarines Sur, which island consists of Lot Nos. 6972 and 6973, in the concept of owners.
On December 6, 1934, the Bureau of Lands approved a survey plan (Survey Plan) in favor of Julio Padayao (the son of Mario Padayao and predecessor-in-interest of Petitioner Dante Padayao) over Lot Nos. 6972 and 6973, which Survey Plan showed that the Padayaos had formally applied for a free patent.
From 1945 to 2009, Mario Padayao and the Heirs of Mario Padayao religiously and continuously declared Pitogo Island for taxation purposes and paid the corresponding real property taxes, as evidenced by a Certification dated February 13, 2009 issued by the Office of the Municipal Treasurer of Caramoan, Camarines Sur.
On June 26, 1976, a catastrophic fire razed the Provincial Capitol of Camarines Sur in Naga City, Naga City, which fire destroyed all registry documents and records of the Register of Deeds of Camarines Sur, including the registration of Free Patent No. 18000 previously issued in favor of Julio Padayao over Pitogo Island.
On January 6, 2009, the Provincial Government of Camarines Sur, through the Acting Chief Provincial Legal Officer, Atty. Janis Ian Regaspi-Cleofe, sent a Letter to Rowel Padayao and other residents of Pitogo Island, informing the residents of Pitogo Island that the residents must vacate Pitogo Island within ten days from receipt because Pitogo Island was allegedly considered a protected area and part of a danger zone.
On January 20, 2009, armed men representing the Provincial Government of Camarines Sur, together with respondents Luis Zulueta, Jovie Villareal, and Dondon Obias, landed on Pitogo Island and ordered the residents to vacate Pitogo Island under threat of immediate demolition, which incident Petitioner Dante Padayao recorded in a police blotter report at the Caramoan Municipal Police Station.
On February 2, 2009, Atty. Thomas C. Uy, Jr., acting as the counsel for the Padayaos, sent a Letter to Atty. Cleofe, asserting that Pitogo Island was private property covered by Free Patent No. 18000 issued in favor of Julio Padayao, who had been in open, continuous, exclusive, notorious, and adverse possession since 1931, and explaining that the physical patent was destroyed in the 1976 Naga City fire.
On February 4, 2009, the Provincial Government of Camarines Sur, through respondents Jose Francisco L. Musa, Jr. (Head of Sagip Kalikasan, Bantay Dagat, and Civil Security Unit) and Jovie Villareal, accompanied by more than twenty heavily armed men of the Civil Security Unit, executed a unilateral and forced eviction, demolishing the residential structures of the occupants of Pitogo Island, including the house of Petitioner Dante Padayao, and forcing Petitioner Dante Padayao to leave Pitogo Island and sell the livestock (goats and cows) of Petitioner Dante Padayao at a significant loss.
Following the demolition, Petitioner Dante Padayao reported the forced dispossession to the Protected Area Management Board (PAMB), which convened a meeting where Provincial Budget Officer Fortunato Peña formally admitted that the notice of demolition was erroneously served on the residents because Pitogo Island was not a protected area of the Department of Environment and Natural Resources (DENR) but was classified as alienable and disposable.
On January 20, 2010, Petitioner Dante Padayao filed a Complaint for recovery of possession (accion publiciana) and damages, with an application for a temporary restraining order and/or a writ of preliminary mandatory injunction, against respondents before the Regional Trial Court of San Jose, Camarines Sur, Branch 30, which Complaint was docketed as Civil Case No. T-1133.
On January 27, 2010, the Land Registration Authority approved Katibayan ng Orihinal na Titulo Bilang 35669 (KOT Blg. 35669) for Lot No. 6973 (the titled lot) in favor of the Heirs of Mario Padayao, represented by Petitioner Dante Padayao.
On July 27, 2010, the Register of Deeds of Camarines Sur officially registered KOT Blg. 35669, establishing Torrens ownership over Lot No. 6973 in the name of the Heirs of Mario Padayao.
On May 16, 2012, the Regional Trial Court of San Jose, Camarines Sur, Branch 30, issued an Order granting Petitioner Dante Padayao's prayer for a writ of preliminary mandatory injunction, ordering the provisional restoration of possession of the properties to Petitioner Dante Padayao pending a final determination on the merits.
On April 27, 2018, the Regional Trial Court rendered a Decision in favor of Petitioner Dante Padayao, ordering respondents to peacefully vacate, turn over, and restore possession of the entire Pitogo Island, consisting of both Lot Nos. 6972 and 6973, to Petitioner Dante Padayao, after finding that Pitogo Island was alienable and disposable public land based on Land Classification Map No. 882.
On September 25, 2018, the Regional Trial Court issued an Order denying the motion for reconsideration filed by respondents, prompting respondents to appeal the Decision to the Court of Appeals.
On May 25, 2021, the Court of Appeals First Division rendered a Decision in CA-G.R. CV No. 112165, partly granting the appeal of respondents and modifying the Regional Trial Court Decision by holding that Petitioner Dante Padayao was entitled to the restoration of possession only with respect to Lot No. 6973 (the titled lot) but not Lot No. 6972 (the untitled lot), on the ground that Lot No. 6972 was presumed to be inalienable public land under the Regalian doctrine.
On April 22, 2022, the Court of Appeals Special First Division issued a Resolution denying the motions for reconsideration filed by both Petitioner Dante Padayao and respondents, leading Petitioner Dante Padayao to elevate the case to the Supreme Court of the Philippines via an Appeal by Certiorari under Rule 45.
On January 15, 2025, the Supreme Court of the Philippines Third Division promulgated the Decision, written by Associate Justice Henri Jean Paul B. Inting, which granted the petition of Petitioner Dante Padayao, reversed and set aside the partial dismissal of the Court of Appeals, and reinstated the Regional Trial Court Decision ordering the full restoration of both Lot Nos. 6972 and 6973 to Petitioner Dante Padayao.

III. Arguments of the Parties

A. Petitioner/Prosecution:

Petitioner Dante Padayao argues that the Court of Appeals committed a reversible error in restricting the right of possession of Petitioner Dante Padayao solely to Lot No. 6973, as Petitioner Dante Padayao presented sufficient, competent, and uncontradicted proof to establish a better right of possession (possession de jure) over both Lot Nos. 6972 and 6973.
Petitioner Dante Padayao contends that Pitogo Island is entirely classified as alienable and disposable public land, as conclusively established by the testimony of Protected Area Superintendent Manuel Tengco, Jr., the official Land Classification Cadastral Map 882 (Land Map 882) certified by the DENR Bureau of Forestry on April 28, 1931, and the subsequent administrative findings of the Protected Area Management Board (PAMB).
Petitioner Dante Padayao asserts that the approved 1934 Survey Plan covers both Lot Nos. 6972 and 6973, thereby demonstrating that the predecessors-in-interest of Petitioner Dante Padayao had actively applied for a free patent and exercised specific acts of ownership over both lots as a single contiguous parcel.
Petitioner Dante Padayao maintains that the open, continuous, exclusive, notorious, and adverse possession of the properties by Petitioner Dante Padayao and the predecessors-in-interest of Petitioner Dante Padayao since 1920 (spanning eighty-nine years prior to the forced eviction) is uncontested, as respondents failed to present any evidence of prior possession or superior title.
Petitioner Dante Padayao claims that Torrens titles issued pursuant to a free patent, such as KOT Blg. 35669, are indefeasible and cannot be collaterally attacked by respondents in an accion publiciana, and that any challenge to the validity of the patent must be raised exclusively through a direct reversion suit initiated by the Solicitor General.

B. Respondent/Defense:

Respondents argue that Petitioner Dante Padayao has no possessory or proprietary right over Lot No. 6972 because Lot No. 6972 is unregistered public land that remains within the public domain and is thus presumed to be inalienable under the Regalian doctrine.
Respondents contend that Petitioner Dante Padayao failed to present incontrovertible evidence of a positive act of the government (such as an executive order or a presidential proclamation) declassifying Pitogo Island as agricultural land, and that the certifications and maps submitted by Petitioner Dante Padayao are legally insufficient to prove alienability.
Respondents assert that Manuel Tengco, Jr., in the capacity of Manuel Tengco, Jr. as a Public Land Inspector, lacks the administrative authority to classify or reclassify public lands, and that the testimony of Manuel Tengco, Jr. and the blueprint of Land Map 882 have no probative value.
Respondents maintain that the eviction of the residents and the subsequent demolition of the structures on February 4, 2009 constituted a valid and lawful exercise of the police power of the State, designed to protect the environment and preserve Pitogo Island as an ecologically threatened zone and a danger zone.
Respondents argue that because the dispossession of Petitioner Dante Padayao occurred on February 4, 2009, and the Complaint was filed on January 20, 2010, the action was filed within one year and therefore qualified as a summary action for forcible entry under Rule 70 of the Rules of Court, meaning that the Regional Trial Court lacked original jurisdiction to hear the case.

C. Common Ground:

The parties do not dispute that Pitogo Island consists of Lot Nos. 6972 and 6973, and that Lot No. 6973 is covered by KOT Blg. 35669 issued in the name of the Heirs of Mario Padayao.
The parties admit that the Provincial Government of Camarines Sur served a notice to vacate on January 6, 2009 and subsequently executed a demolition of the residential houses on Pitogo Island on February 4, 2009, which demolition dispossessed Petitioner Dante Padayao of the property.
The parties agree that all registry records and documents of the Register of Deeds of Camarines Sur were destroyed by a fire that razed the Provincial Capitol of Camarines Sur on June 26, 1976.

IV. Issues

A. MAIN ISSUE:

Whether the Court of Appeals committed a reversible error in restricting Petitioner Dante Padayao's right of possession solely to Lot No. 6973 on the ground that Lot No. 6972 is presumed to be inalienable public land, or whether Petitioner Dante Padayao established a better right of possession (possession de jure) over both Lot Nos. 6972 and 6973 in an accion publiciana, on the basis of uncontested prior possession since 1920 and Land Classification Map No. 882 showing that Pitogo Island is alienable and disposable.

B. SECONDARY ISSUES:

Whether the Regional Trial Court had original jurisdiction over Civil Case No. T-1133, given that the Complaint failed to allege the assessed value of Pitogo Island as required by Section 19 of Batas Pambansa Blg. 129, and whether respondents are estopped from challenging the jurisdiction of the Regional Trial Court after actively participating in the trial and appeal without raising the jurisdictional defect.
Whether the unilateral eviction of the occupants and the subsequent demolition of the residential structures on Pitogo Island by respondents constituted a valid and lawful exercise of the police power of the State, or whether the actions of respondents were arbitrary and violative of the due process clause.
Whether respondents can collaterally attack the validity of the free patent title (KOT Blg. 35669) in an accion publiciana on the ground that the land is a protected area, or whether the patent title is indefeasible and can only be assailed through a direct reversion suit initiated by the Solicitor General under Section 101 of the Public Land Act.

V. Ruling / Disposition

A. RULING ON THE MAIN ISSUE:

YES. The Supreme Court of the Philippines ruled that the Court of Appeals erred in limiting Petitioner Dante Padayao's right of possession to Lot No. 6973. In an accion publiciana, the sole issue for resolution is the better right of possession (possession de jure) independent of ownership, and any provisional determination of ownership does not bind the title of the property with finality. The Supreme Court held that Petitioner Dante Padayao sufficiently proved a better right of possession over both Lot Nos. 6972 and 6973. First, the uncontested prior possession of Petitioner Dante Padayao and the predecessors-in-interest of Petitioner Dante Padayao since 1920 is superior to the claim of respondents, who are mere intruders with no possessory or proprietary right. Second, the Supreme Court, applying the En Banc guidelines in Republic v. Pasig Rizal Co., Inc. and Section 7 of Republic Act No. 11573, held that Land Classification Map No. 882 (certified by the DENR Bureau of Forestry on April 28, 1931) is reliable and sufficient proof that the entire Pitogo Island, including Lot No. 6972, is alienable and disposable public land. Once public land is classified as alienable and disposable, the land ceases to be public dominion land and is converted into patrimonial property of the State, making the land susceptible to private possession and acquisition. Thus, the presumption of inalienability was successfully overcome, confirming Petitioner Dante Padayao's right of possession.

B. RULING ON SECONDARY ISSUE NO. 1:

YES, but with qualification. The Supreme Court of the Philippines ruled that while the Complaint failed to allege the assessed value of the real property (which is a jurisdictional requirement for real actions under Section 19 of Batas Pambansa Blg. 129), and although the Regional Trial Court should have dismissed the Complaint on that ground, respondents are estopped from challenging the Regional Trial Court's jurisdiction. The respondents actively participated in all stages of the proceedings, submitted pleadings, presented witnesses, appealed to the Court of Appeals, and only raised the jurisdictional defect for the first time before the Supreme Court. Under the doctrine of estoppel, a party cannot invoke the jurisdiction of a court to secure affirmative relief and then repudiate that same jurisdiction after failing to obtain a favorable judgment.

C. RULING ON SECONDARY ISSUE NO. 2:

NO. The Supreme Court of the Philippines ruled that respondents' arbitrary eviction and demolition under the guise of police power was unlawful, void, and arbitrary. Although the State possesses the inherent power of police power, the police power cannot be exercised arbitrarily, whimsically, or without due process of law. Respondents failed to present any official declaration or map from the DENR or the PAMB classifying Pitogo Island as a protected area or a danger zone under the National Integrated Protected Areas System (NIPAS) Act (Republic Act No. 7586). Furthermore, Proclamation No. 291, which established the Caramoan National Park, did not cover the entire municipality of Caramoan and did not include Pitogo Island. Respondents' own budget officer admitted that the notices were served in error. Consequently, respondents' unilateral destruction of Dante Padayao's structures on February 4, 2009 was a flagrant violation of the due process clause.

D. RULING ON SECONDARY ISSUE NO. 3:

NO. The Supreme Court of the Philippines ruled that respondents cannot collaterally attack KOT Blg. 35669. A Torrens title issued pursuant to a free patent enjoys the presumption of validity and becomes indefeasible. Under Section 101 of the Public Land Act, any action for the reversion of land to the public domain on the ground of fraud or illegality in the patent's issuance must be instituted exclusively by the Solicitor General in the name of the Republic of the Philippines. Respondents have no personality to collaterally attack the title in an accion publiciana.

VERBATIM DISPOSITIVE PORTION: The Supreme Court of the Philippines' final dispositive portion in G.R. No. 260415 is quoted verbatim as follows:

"WHEREFORE, the petition is GRANTED. The Decision dated May 25, 2021 and Resolution dated April 22, 2022 of the Court of Appeals in CA-G.R. CV No. 112165 are AFFIRMED with MODIFICATION in that respondents Gov. Luis Raymund F. Villafuerte, Jr., Atty. Janis Ian Regaspi-Cleofe, Jose Francisco L. Musa, Jr., Luis Zulueta, Jovie Villareal, Dondon Obias and the Provincial Government of Camarines Sur, as well as every other individual and/or individuals, whether claiming, using and/or exercising rights under them, are ORDERED to vacate, turn over, and restore possession of Lot Nos. 6972 and 6973, the latter covered by Katibayan ng Orihinal na Titulo Bilang 35669, to petitioner Punong Barangay Dante Padayao.

SO ORDERED."

VI. Ratio Decidendi and Doctrines

A. Ratio Decidendi:

The Provisional Nature of Ownership in Accion Publiciana: Under established property law, the sole issue in an accion publiciana is the better right of possession (possession de jure), which is entirely independent of ownership. While the Regional Trial Court may provisionally resolve the issue of ownership to determine who has the better right to possess, such provisional determination is not conclusive on the title of the property and does not bar a separate, direct action to settle ownership with finality.
Prior Possession as a Better Right: In possessory disputes, the party who proves prior physical possession (possession de facto) in the concept of an owner possesses a better right against a mere intruder or usurper who has no possessory or proprietary title. Petitioner Dante Padayao's uninterrupted possession of Lot Nos. 6972 and 6973 since 1920 constitutes prior possession that must be protected against respondents' arbitrary dispossession in 2009.
The Operative Act of Land Classification: The En Banc doctrine in Republic v. Pasig Rizal Co., Inc. holds that the classification of public agricultural land as alienable and disposable by the State is the operative act that converts the property from public dominion to patrimonial property of the State, as this classification serves as the positive manifestation of the State's lack of intent to retain the land for some public use or service.
The Simplified Standard of Proof for Alienability: Under Section 7 of Republic Act No. 11573, which simplifies the confirmation process for imperfect titles, the old, rigid requirements under Republic v. T.A.N. Properties, Inc. (requiring a certified true copy of the original land classification approved by the DENR Secretary) have been superseded. A land classification map, such as Land Classification Map No. 882 certified by the Bureau of Forestry on April 28, 1931, constitutes reliable, competent, and sufficient proof of the alienable and disposable character of public land.
Estoppel on Jurisdictional Defects: Although the assessed value of real property is a jurisdictional element under Section 19 of Batas Pambansa Blg. 129 to determine whether the Regional Trial Court or the Municipal Trial Court has original jurisdiction, a party who actively participates in the litigation, presents evidence, and appeals the decision without raising the jurisdictional defect is barred by estoppel from questioning the court's jurisdiction for the first time on appeal.
The Exclusivity of Reversion Suits: Under Section 101 of Commonwealth Act No. 141, all actions for the reversion of lands of the public domain or the cancellation of free patents on the ground of fraud, mistake, or illegality must be instituted exclusively by the Solicitor General in the name of the Republic of the Philippines. A Torrens title issued pursuant to a public land grant cannot be collaterally attacked by private parties or local government units in a possessory action.
The Limits of Police Power: Although local government units possess the inherent power of police power, the police power cannot be exercised arbitrarily, whimsically, or without observing the constitutional guarantee of due process. The unilateral eviction of residents and the destruction of private structures based on unsubstantiated assertions of a "protected area" or "danger zone," without any supporting official declaration or map from the DENR, constitutes an oppressive and void exercise of municipal authority.

B. Doctrines/Rules:

The Rule on Provisional Possession: In an accion publiciana, the regular court has the authority to provisionally resolve the issue of ownership solely for the purpose of determining the better right of possession. Such provisional determination is not conclusive on the title and does not bind the property with finality.
The Rule on the Sufficiency of Land Classification Maps: Pursuant to Section 7 of Republic Act No. 11573, as interpreted in Republic v. Pasig Rizal Co., Inc., a land classification map approved by the proper approving authority constitutes reliable and sufficient proof to establish the alienable and disposable status of public land, declassifying the property from public dominion into patrimonial property susceptible to private possession.
The Rule on Estoppel in Jurisdiction: A party who has actively participated in the litigation, presented evidence, and sought affirmative relief before a court is estopped from subsequently challenging the jurisdiction of the said court on the ground of an omission of a jurisdictional element in the complaint.
The Rule on the Inherent Protection of Torrens Titles: A Torrens certificate of title, whether issued judicially or administratively pursuant to a free patent or homestead patent, is indefeasible and cannot be subjected to a collateral attack. Under Section 101 of Commonwealth Act No. 141, the patent title can only be assailed through a direct reversion suit initiated by the Solicitor General.

C. Limitations/Exceptions:

The Limit on Provisional Adjudication: The Regional Trial Court's provisional determination of ownership in an accion publiciana is strictly limited to resolving the issue of possession and does not bar a separate, direct action (such as quiet title, cancellation of title, or partition) before a court of competent jurisdiction to settle the issue of ownership with finality.
The Limit on Private Reversion Actions: The rule restricting reversion suits exclusively to the Solicitor General does not apply where a private claimant seeks a direct reconveyance from a defendant who has unlawfully and in breach of trust titled public land in the defendant's name, under the principle of enforcing a constructive trust under Article 1456 of the Civil Code. However, this exception is inapplicable where the State is not a party and no constructive trust is alleged.
The Procedural Restriction on Injunctions: A writ of possession or preliminary mandatory injunction is essentially an order to place the prevailing party in possession of the property, but in implementing the writ, the sheriff cannot remove or demolish the improvements except upon a special order of the court issued after a hearing under Section 10 of Rule 39 of the Rules of Court.

D. Topic Integration:

The case of Padayao v. Villafuerte, Jr. is a landmark application of the simplified land registration rules under Republic Act No. 11573 and Republic v. Pasig Rizal Co., Inc. in the context of possessory actions. The decision directly integrates with the syllabus topic of original registration by clarifying that the "alienable and disposable" character of public land—which is a prerequisite for registration under Section 14, paragraph 1 of Presidential Decree No. 1529—can be provisionally proved in an ordinary civil action using a land classification map (such as Land Classification Map No. 882 certified by the Bureau of Forestry in 1931). By holding that the declassification of public dominion land into patrimonial land occurs by virtue of the land classification map, the Supreme Court protects the possessory rights of public land occupants whose possession began before the formal issuance of a Torrens title. This case harmonizes the administrative functions of the DENR with the judicial policy of protecting prior lawful possessors from arbitrary state evictions, reinforcing the constitutional mandate that no person shall be deprived of property without due process of law.

VII. Separate Opinions

NONE. The decision of the Supreme Court of the Philippines in G.R. No. 260415 was rendered unanimously by the Third Division, with no separate concurring or dissenting opinions filed by the participating Justices.

Cited Laws & Provisions

Every statute, rule, and issuance the decision turns on — the text as written, and the work it does in this case.

Civil Code

Article 539, Civil Code

Civil Code of the Philippines (R.A. No. 386), Book II (Property, Ownership, and Its Modifications), Title V (Possession), Chapter 3 (Effects of Possession)

Every possessor has a right to be respected in his possession; and should he be disturbed therein he shall be protected in or restored to said possession by the means established by the laws and the Rules of Court.

A possessor deprived of his possession through forcible entry may within ten days from the filing of the complaint present a motion to secure from the competent court, in the action for forcible entry, a writ of preliminary mandatory injunction to restore him in his possession. The court shall decide the motion within thirty (30) days from the filing thereof. (446a)

Why it is cited here

The right actually sued on, and the reason the registration standard did not apply.

"Every possessor has a right to be respected in his possession; and should he be disturbed therein he shall be protected in or restored to said possession by the means established by the laws and the Rules of Court."

Dante Padayao brought an accion publiciana, not an application for registration. The question was who has the better right of possession, and the answer does not require proving ownership against the world.

That distinction decides the case. In a registration proceeding the applicant carries the Regalian burden and must affirmatively prove the land alienable and disposable. In a possessory action he need only show a better right than the defendant's — here, against a Provincial Government that forcibly evicted the family and demolished their structures.

So the Court of Appeals erred in kind, not merely in degree. It applied a registration requirement to a possessory action, and asked Dante to disprove a presumption that the form of his suit never put in issue.

Special Law

Section 7, R.A. No. 11573

Proof that the Land is Alienable and Disposable

Republic Act No. 11573 (2021) — An Act Improving the Confirmation Process for Imperfect Land Titles

For purposes of judicial confirmation of imperfect titles filed under Presidential Decree No. 1529, a duly signed certification by a duly designated DENR geodetic engineer that the land is part of alienable and disposable agricultural lands of the public domain is sufficient proof that the land is alienable. Said certification shall be imprinted in the approved survey plan submitted by the applicant in the land registration court. The imprinted certification in the plan shall contain a sworn statement by the geodetic engineer that the land is within the alienable and disposable lands of the public domain and shall state the applicable Forestry Administrative Order, DENR Administrative Order, Executive Order, Proclamations and the Land Classification Project Map Number covering the subject land.

Should there be no available copy of the Forestry Administrative Order, Executive Order or Proclamation, it is sufficient that the Lad Classification (LC) Map Number, Project Number, and date of release indicated in the land classification map be stated in the sworn statement declaring that said land classification map is existing in the inventory of LC Map records of the National Mapping and Resource Information Authority (NAMRIA) and is being used by the DENR as land classification map.

Why it is cited here

Where the alienability evidence came from, and why one lot's proof carried the other.

Alienability is proved by a duly signed certification by a duly designated DENR geodetic engineer, imprinted in the approved survey plan.

Lot No. 6973 was titled; Lot No. 6972 adjoined it and was untitled. The CA restored possession of the first and refused the second, reasoning that Dante had not overcome the presumption that untitled land is inalienable public land.

The Court reversed, on a point of evidence rather than of doctrine: both lots lie within the same island, so evidence of Lot 6973's alienable and disposable character applies equally to Lot 6972. Classification attaches to areas, not to parcels — a classification map covers terrain, and a boundary drawn later does not split it.

The practical instruction is worth keeping: check whether the classification instrument covers the wider area. Proof already in the record for a neighbouring lot may dispose of the question without any new certification.

Civil Code

Article 422, Civil Code

Civil Code of the Philippines (R.A. No. 386), Book II (Property, Ownership, and Its Modifications), Title I (Classification of Property), Chapter 3 (Property in Relation to the Person to Whom It Belongs)

Property of public dominion, when no longer intended for public use or for public service, shall form part of the patrimonial property of the State. (341a)

Why it is cited here

The step that made the untitled lot capable of private possession at all.

"Property of public dominion, when no longer intended for public use or for public service, shall form part of the patrimonial property of the State."

The Court invoked Republic v. Pasig Rizal Co.'s reading: classification as alienable and disposable is itself the "operative act" converting public dominion land into patrimonial property — absent prior public use.

That qualifier is the whole of the refinement, and it is easy to misread Malabanan without it. The express government declaration Malabanan requires is needed only where the land was previously dedicated to public use or service; where nothing was ever dedicated, there is nothing to un-dedicate, and A&D classification does the work by itself.

Applied here: Pitogo Island was not shown to have been put to any prior public use, so the classification sufficed — and the Provincial Government's late characterisation of it as a protected danger zone was an assertion about safety, not a prior dedication that would have kept the land in public dominion.

Source: Padayao v. Villafuerte, Jr., G.R. No. 260415, January 15, 2025

Cited laws & provisions

Article 539, Civil Code

Civil Code

Civil Code of the Philippines (R.A. No. 386), Book II (Property, Ownership, and Its Modifications), Title V (Possession), Chapter 3 (Effects of Possession)

Why it is cited here

The right actually sued on, and the reason the registration standard did not apply.

Full entry below ↓

Section 7, R.A. No. 11573

Special Law

Proof that the Land is Alienable and Disposable

Republic Act No. 11573 (2021) — An Act Improving the Confirmation Process for Imperfect Land Titles

Why it is cited here

Where the alienability evidence came from, and why one lot's proof carried the other.

Alienability is proved by a duly signed certification by a duly designated DENR geodetic engineer, imprinted in the approved survey plan.

Full entry below ↓

Article 422, Civil Code

Civil Code

Property of public dominion, when no longer intended for public use or for public service, shall form part of the patrimonial property of the State. (341a)

Why it is cited here

The step that made the untitled lot capable of private possession at all.

"Property of public dominion, when no longer intended for public use or for public service, shall form part of the patrimonial property of the State."

Full entry below ↓

Facts

The Padayaos occupied Pitogo Island since 1920 by Dante's account.
Predecessor Julio obtained a 1934 survey plan and allegedly a free patent, later lost in the 1976 Provincial Capitol fire.
The Municipal Treasurer certified that Mario Padayao paid real property taxes for the island from 1945 to 2009.
On January 6, 2009, the Provincial Government demanded the residents vacate within ten days as a protected danger zone.
Armed men reinforced the threat on January 20, and roughly twenty demolished Dante's and other structures on February 4.
Dante sued for recovery of possession and damages before the RTC on January 20, 2010 — within one year of the demolition.
DENR witness Tengco testified the island was alienable and disposable per Land Classification Map No. 882, certified by the Bureau of Forestry in 1931, and that a PAMB meeting confirmed it was not DENR-protected.
A Katibayan ng Orihinal na Titulo (KOT Blg. 35669) issued in 2010 to the Heirs of Mario for Lot No. 6973, based on a 2008 free-patent application.
Respondents defended the demolition as an exercise of police power over an environmentally threatened area, offering residents financial assistance to relocate voluntarily.
The RTC's April 27, 2018 Decision ordered respondents to vacate and restore both lots to Dante.
The CA's May 25, 2021 Decision affirmed with modification, restoring possession only as to titled Lot 6973, holding Dante failed to prove ownership of untitled Lot 6972, deemed presumptively inalienable.
Both parties' motions for reconsideration were denied, and Dante filed this Rule 45 petition.

Arguments of the Parties

Issue

SECONDARY ISSUES. Whether the RTC retained jurisdiction over the accion publiciana despite the Complaint's failure to allege the properties' assessed value.

Ruling

Ratio

Quoting Pasig Rizal Co., the Court reasoned that "[t]he operative act which converts property of public dominion to patrimonial property is its classification as alienable and disposable land of the public domain, as this classification precisely serves as the manifestation of the State's lack of intent to retain the same for some public use or purpose."
Since Land Map 882 and Tengco's testimony went unrebutted, the Court held "if Land Map 882 and the testimony of Tengco are given credence as to the nature of Lot No. 6973, then it should be the same with Lot No. 6972."
On possession, the Court clarified: "Dante does not seek to obtain title over Lot No. 6972 but only to establish that he has a better right of possession than respondents," his "prior possession... is uncontested and... adequately established," including respondents' own characterization of the demolition as a "relocation of the Pitogo island occupants."
On jurisdiction, the Court held respondents "are estopped from averring it," having "never pointed out the foregoing errors" despite having "actively participated in the case."

Doctrine

Doctrines / Rules / Principles Laid Down.

Classification of land as alienable and disposable is itself the operative act converting public dominion property into patrimonial property, requiring no express government declaration where no prior public use is alleged.
In an accion publiciana, ownership and title validity are resolved only provisionally, to determine the better right of possession; the claimant need not establish a Section 14(1)-grade chain of title.
A party who actively litigates without timely raising a jurisdictional defect apparent on the complaint's face is later estopped from invoking it.

Distinctions / Limitations / Qualifications.

Unlike a Section 14(1) proceeding, which demands affirmative proof of OCEN possession since June 12, 1945 (or the amended statutory period) as a precondition to title, an accion publiciana requires only a better right of possession; the 1945 tax-payment evidence here merely corroborated possession, without triggering Section 14(1) adjudication.

Topic/Subtopic Integration (Mandatory).

ANALOGOUS: the case does not adjudicate a Section 14(1) application, but applies Pasig Rizal Co.'s land-classification doctrine — directly pertinent to the Third Requisite's broader jurisprudential context — and illustrates, by contrast, how much less an accion publiciana claimant must prove regarding possession and land status than a Section 14(1) registration applicant.

Separate Opinions

None. Gaerlan and Dimaampao, JJ., concurred; Caguioa, J., was on official business, and Singh, J., was on leave — no separate opinions were written.

Full Digest — Recitation Format

Full-length digest in the format required by the course digest prompt.

Classification: INCIDENTAL · G.R. No. 260415, January 15, 2025

TOPIC/SUBTOPIC FOCUS: No. 141, the Public Land Act, and P.D. No. 1529, the Property Registration Decree, Republic Act No. 11573, July 16, 2021

I. Gist and Central Doctrine

II. Chronological Narration of Material Facts

In 1920, Petitioner Dante Padayao and the predecessors-in-interest of Petitioner Dante Padayao entered into the actual, open, continuous, and peaceful possession and cultivation of Pitogo Island, Caramoan, Camarines Sur, which island consists of Lot Nos. 6972 and 6973, in the concept of owners.
On December 6, 1934, the Bureau of Lands approved a survey plan (Survey Plan) in favor of Julio Padayao (the son of Mario Padayao and predecessor-in-interest of Petitioner Dante Padayao) over Lot Nos. 6972 and 6973, which Survey Plan showed that the Padayaos had formally applied for a free patent.
From 1945 to 2009, Mario Padayao and the Heirs of Mario Padayao religiously and continuously declared Pitogo Island for taxation purposes and paid the corresponding real property taxes, as evidenced by a Certification dated February 13, 2009 issued by the Office of the Municipal Treasurer of Caramoan, Camarines Sur.
On June 26, 1976, a catastrophic fire razed the Provincial Capitol of Camarines Sur in Naga City, Naga City, which fire destroyed all registry documents and records of the Register of Deeds of Camarines Sur, including the registration of Free Patent No. 18000 previously issued in favor of Julio Padayao over Pitogo Island.
On January 6, 2009, the Provincial Government of Camarines Sur, through the Acting Chief Provincial Legal Officer, Atty. Janis Ian Regaspi-Cleofe, sent a Letter to Rowel Padayao and other residents of Pitogo Island, informing the residents of Pitogo Island that the residents must vacate Pitogo Island within ten days from receipt because Pitogo Island was allegedly considered a protected area and part of a danger zone.
On January 20, 2009, armed men representing the Provincial Government of Camarines Sur, together with respondents Luis Zulueta, Jovie Villareal, and Dondon Obias, landed on Pitogo Island and ordered the residents to vacate Pitogo Island under threat of immediate demolition, which incident Petitioner Dante Padayao recorded in a police blotter report at the Caramoan Municipal Police Station.
On February 2, 2009, Atty. Thomas C. Uy, Jr., acting as the counsel for the Padayaos, sent a Letter to Atty. Cleofe, asserting that Pitogo Island was private property covered by Free Patent No. 18000 issued in favor of Julio Padayao, who had been in open, continuous, exclusive, notorious, and adverse possession since 1931, and explaining that the physical patent was destroyed in the 1976 Naga City fire.
On February 4, 2009, the Provincial Government of Camarines Sur, through respondents Jose Francisco L. Musa, Jr. (Head of Sagip Kalikasan, Bantay Dagat, and Civil Security Unit) and Jovie Villareal, accompanied by more than twenty heavily armed men of the Civil Security Unit, executed a unilateral and forced eviction, demolishing the residential structures of the occupants of Pitogo Island, including the house of Petitioner Dante Padayao, and forcing Petitioner Dante Padayao to leave Pitogo Island and sell the livestock (goats and cows) of Petitioner Dante Padayao at a significant loss.
Following the demolition, Petitioner Dante Padayao reported the forced dispossession to the Protected Area Management Board (PAMB), which convened a meeting where Provincial Budget Officer Fortunato Peña formally admitted that the notice of demolition was erroneously served on the residents because Pitogo Island was not a protected area of the Department of Environment and Natural Resources (DENR) but was classified as alienable and disposable.
On January 20, 2010, Petitioner Dante Padayao filed a Complaint for recovery of possession (accion publiciana) and damages, with an application for a temporary restraining order and/or a writ of preliminary mandatory injunction, against respondents before the Regional Trial Court of San Jose, Camarines Sur, Branch 30, which Complaint was docketed as Civil Case No. T-1133.
On January 27, 2010, the Land Registration Authority approved Katibayan ng Orihinal na Titulo Bilang 35669 (KOT Blg. 35669) for Lot No. 6973 (the titled lot) in favor of the Heirs of Mario Padayao, represented by Petitioner Dante Padayao.
On July 27, 2010, the Register of Deeds of Camarines Sur officially registered KOT Blg. 35669, establishing Torrens ownership over Lot No. 6973 in the name of the Heirs of Mario Padayao.
On May 16, 2012, the Regional Trial Court of San Jose, Camarines Sur, Branch 30, issued an Order granting Petitioner Dante Padayao's prayer for a writ of preliminary mandatory injunction, ordering the provisional restoration of possession of the properties to Petitioner Dante Padayao pending a final determination on the merits.
On April 27, 2018, the Regional Trial Court rendered a Decision in favor of Petitioner Dante Padayao, ordering respondents to peacefully vacate, turn over, and restore possession of the entire Pitogo Island, consisting of both Lot Nos. 6972 and 6973, to Petitioner Dante Padayao, after finding that Pitogo Island was alienable and disposable public land based on Land Classification Map No. 882.
On September 25, 2018, the Regional Trial Court issued an Order denying the motion for reconsideration filed by respondents, prompting respondents to appeal the Decision to the Court of Appeals.
On May 25, 2021, the Court of Appeals First Division rendered a Decision in CA-G.R. CV No. 112165, partly granting the appeal of respondents and modifying the Regional Trial Court Decision by holding that Petitioner Dante Padayao was entitled to the restoration of possession only with respect to Lot No. 6973 (the titled lot) but not Lot No. 6972 (the untitled lot), on the ground that Lot No. 6972 was presumed to be inalienable public land under the Regalian doctrine.
On April 22, 2022, the Court of Appeals Special First Division issued a Resolution denying the motions for reconsideration filed by both Petitioner Dante Padayao and respondents, leading Petitioner Dante Padayao to elevate the case to the Supreme Court of the Philippines via an Appeal by Certiorari under Rule 45.
On January 15, 2025, the Supreme Court of the Philippines Third Division promulgated the Decision, written by Associate Justice Henri Jean Paul B. Inting, which granted the petition of Petitioner Dante Padayao, reversed and set aside the partial dismissal of the Court of Appeals, and reinstated the Regional Trial Court Decision ordering the full restoration of both Lot Nos. 6972 and 6973 to Petitioner Dante Padayao.

III. Arguments of the Parties

A. Petitioner/Prosecution:

Petitioner Dante Padayao argues that the Court of Appeals committed a reversible error in restricting the right of possession of Petitioner Dante Padayao solely to Lot No. 6973, as Petitioner Dante Padayao presented sufficient, competent, and uncontradicted proof to establish a better right of possession (possession de jure) over both Lot Nos. 6972 and 6973.
Petitioner Dante Padayao contends that Pitogo Island is entirely classified as alienable and disposable public land, as conclusively established by the testimony of Protected Area Superintendent Manuel Tengco, Jr., the official Land Classification Cadastral Map 882 (Land Map 882) certified by the DENR Bureau of Forestry on April 28, 1931, and the subsequent administrative findings of the Protected Area Management Board (PAMB).
Petitioner Dante Padayao asserts that the approved 1934 Survey Plan covers both Lot Nos. 6972 and 6973, thereby demonstrating that the predecessors-in-interest of Petitioner Dante Padayao had actively applied for a free patent and exercised specific acts of ownership over both lots as a single contiguous parcel.
Petitioner Dante Padayao maintains that the open, continuous, exclusive, notorious, and adverse possession of the properties by Petitioner Dante Padayao and the predecessors-in-interest of Petitioner Dante Padayao since 1920 (spanning eighty-nine years prior to the forced eviction) is uncontested, as respondents failed to present any evidence of prior possession or superior title.
Petitioner Dante Padayao claims that Torrens titles issued pursuant to a free patent, such as KOT Blg. 35669, are indefeasible and cannot be collaterally attacked by respondents in an accion publiciana, and that any challenge to the validity of the patent must be raised exclusively through a direct reversion suit initiated by the Solicitor General.

B. Respondent/Defense:

Respondents argue that Petitioner Dante Padayao has no possessory or proprietary right over Lot No. 6972 because Lot No. 6972 is unregistered public land that remains within the public domain and is thus presumed to be inalienable under the Regalian doctrine.
Respondents contend that Petitioner Dante Padayao failed to present incontrovertible evidence of a positive act of the government (such as an executive order or a presidential proclamation) declassifying Pitogo Island as agricultural land, and that the certifications and maps submitted by Petitioner Dante Padayao are legally insufficient to prove alienability.
Respondents assert that Manuel Tengco, Jr., in the capacity of Manuel Tengco, Jr. as a Public Land Inspector, lacks the administrative authority to classify or reclassify public lands, and that the testimony of Manuel Tengco, Jr. and the blueprint of Land Map 882 have no probative value.
Respondents maintain that the eviction of the residents and the subsequent demolition of the structures on February 4, 2009 constituted a valid and lawful exercise of the police power of the State, designed to protect the environment and preserve Pitogo Island as an ecologically threatened zone and a danger zone.
Respondents argue that because the dispossession of Petitioner Dante Padayao occurred on February 4, 2009, and the Complaint was filed on January 20, 2010, the action was filed within one year and therefore qualified as a summary action for forcible entry under Rule 70 of the Rules of Court, meaning that the Regional Trial Court lacked original jurisdiction to hear the case.

C. Common Ground:

The parties do not dispute that Pitogo Island consists of Lot Nos. 6972 and 6973, and that Lot No. 6973 is covered by KOT Blg. 35669 issued in the name of the Heirs of Mario Padayao.
The parties admit that the Provincial Government of Camarines Sur served a notice to vacate on January 6, 2009 and subsequently executed a demolition of the residential houses on Pitogo Island on February 4, 2009, which demolition dispossessed Petitioner Dante Padayao of the property.
The parties agree that all registry records and documents of the Register of Deeds of Camarines Sur were destroyed by a fire that razed the Provincial Capitol of Camarines Sur on June 26, 1976.

IV. Issues

A. MAIN ISSUE:

B. SECONDARY ISSUES:

Whether the Regional Trial Court had original jurisdiction over Civil Case No. T-1133, given that the Complaint failed to allege the assessed value of Pitogo Island as required by Section 19 of Batas Pambansa Blg. 129, and whether respondents are estopped from challenging the jurisdiction of the Regional Trial Court after actively participating in the trial and appeal without raising the jurisdictional defect.
Whether the unilateral eviction of the occupants and the subsequent demolition of the residential structures on Pitogo Island by respondents constituted a valid and lawful exercise of the police power of the State, or whether the actions of respondents were arbitrary and violative of the due process clause.
Whether respondents can collaterally attack the validity of the free patent title (KOT Blg. 35669) in an accion publiciana on the ground that the land is a protected area, or whether the patent title is indefeasible and can only be assailed through a direct reversion suit initiated by the Solicitor General under Section 101 of the Public Land Act.

V. Ruling / Disposition

A. RULING ON THE MAIN ISSUE:

B. RULING ON SECONDARY ISSUE NO. 1:

C. RULING ON SECONDARY ISSUE NO. 2:

D. RULING ON SECONDARY ISSUE NO. 3:

VERBATIM DISPOSITIVE PORTION: The Supreme Court of the Philippines' final dispositive portion in G.R. No. 260415 is quoted verbatim as follows:

"WHEREFORE, the petition is GRANTED. The Decision dated May 25, 2021 and Resolution dated April 22, 2022 of the Court of Appeals in CA-G.R. CV No. 112165 are AFFIRMED with MODIFICATION in that respondents Gov. Luis Raymund F. Villafuerte, Jr., Atty. Janis Ian Regaspi-Cleofe, Jose Francisco L. Musa, Jr., Luis Zulueta, Jovie Villareal, Dondon Obias and the Provincial Government of Camarines Sur, as well as every other individual and/or individuals, whether claiming, using and/or exercising rights under them, are ORDERED to vacate, turn over, and restore possession of Lot Nos. 6972 and 6973, the latter covered by Katibayan ng Orihinal na Titulo Bilang 35669, to petitioner Punong Barangay Dante Padayao.

SO ORDERED."

VI. Ratio Decidendi and Doctrines

A. Ratio Decidendi:

The Provisional Nature of Ownership in Accion Publiciana: Under established property law, the sole issue in an accion publiciana is the better right of possession (possession de jure), which is entirely independent of ownership. While the Regional Trial Court may provisionally resolve the issue of ownership to determine who has the better right to possess, such provisional determination is not conclusive on the title of the property and does not bar a separate, direct action to settle ownership with finality.
Prior Possession as a Better Right: In possessory disputes, the party who proves prior physical possession (possession de facto) in the concept of an owner possesses a better right against a mere intruder or usurper who has no possessory or proprietary title. Petitioner Dante Padayao's uninterrupted possession of Lot Nos. 6972 and 6973 since 1920 constitutes prior possession that must be protected against respondents' arbitrary dispossession in 2009.
The Operative Act of Land Classification: The En Banc doctrine in Republic v. Pasig Rizal Co., Inc. holds that the classification of public agricultural land as alienable and disposable by the State is the operative act that converts the property from public dominion to patrimonial property of the State, as this classification serves as the positive manifestation of the State's lack of intent to retain the land for some public use or service.
The Simplified Standard of Proof for Alienability: Under Section 7 of Republic Act No. 11573, which simplifies the confirmation process for imperfect titles, the old, rigid requirements under Republic v. T.A.N. Properties, Inc. (requiring a certified true copy of the original land classification approved by the DENR Secretary) have been superseded. A land classification map, such as Land Classification Map No. 882 certified by the Bureau of Forestry on April 28, 1931, constitutes reliable, competent, and sufficient proof of the alienable and disposable character of public land.
Estoppel on Jurisdictional Defects: Although the assessed value of real property is a jurisdictional element under Section 19 of Batas Pambansa Blg. 129 to determine whether the Regional Trial Court or the Municipal Trial Court has original jurisdiction, a party who actively participates in the litigation, presents evidence, and appeals the decision without raising the jurisdictional defect is barred by estoppel from questioning the court's jurisdiction for the first time on appeal.
The Exclusivity of Reversion Suits: Under Section 101 of Commonwealth Act No. 141, all actions for the reversion of lands of the public domain or the cancellation of free patents on the ground of fraud, mistake, or illegality must be instituted exclusively by the Solicitor General in the name of the Republic of the Philippines. A Torrens title issued pursuant to a public land grant cannot be collaterally attacked by private parties or local government units in a possessory action.
The Limits of Police Power: Although local government units possess the inherent power of police power, the police power cannot be exercised arbitrarily, whimsically, or without observing the constitutional guarantee of due process. The unilateral eviction of residents and the destruction of private structures based on unsubstantiated assertions of a "protected area" or "danger zone," without any supporting official declaration or map from the DENR, constitutes an oppressive and void exercise of municipal authority.

B. Doctrines/Rules:

The Rule on Provisional Possession: In an accion publiciana, the regular court has the authority to provisionally resolve the issue of ownership solely for the purpose of determining the better right of possession. Such provisional determination is not conclusive on the title and does not bind the property with finality.
The Rule on the Sufficiency of Land Classification Maps: Pursuant to Section 7 of Republic Act No. 11573, as interpreted in Republic v. Pasig Rizal Co., Inc., a land classification map approved by the proper approving authority constitutes reliable and sufficient proof to establish the alienable and disposable status of public land, declassifying the property from public dominion into patrimonial property susceptible to private possession.
The Rule on Estoppel in Jurisdiction: A party who has actively participated in the litigation, presented evidence, and sought affirmative relief before a court is estopped from subsequently challenging the jurisdiction of the said court on the ground of an omission of a jurisdictional element in the complaint.
The Rule on the Inherent Protection of Torrens Titles: A Torrens certificate of title, whether issued judicially or administratively pursuant to a free patent or homestead patent, is indefeasible and cannot be subjected to a collateral attack. Under Section 101 of Commonwealth Act No. 141, the patent title can only be assailed through a direct reversion suit initiated by the Solicitor General.

C. Limitations/Exceptions:

The Limit on Provisional Adjudication: The Regional Trial Court's provisional determination of ownership in an accion publiciana is strictly limited to resolving the issue of possession and does not bar a separate, direct action (such as quiet title, cancellation of title, or partition) before a court of competent jurisdiction to settle the issue of ownership with finality.
The Limit on Private Reversion Actions: The rule restricting reversion suits exclusively to the Solicitor General does not apply where a private claimant seeks a direct reconveyance from a defendant who has unlawfully and in breach of trust titled public land in the defendant's name, under the principle of enforcing a constructive trust under Article 1456 of the Civil Code. However, this exception is inapplicable where the State is not a party and no constructive trust is alleged.
The Procedural Restriction on Injunctions: A writ of possession or preliminary mandatory injunction is essentially an order to place the prevailing party in possession of the property, but in implementing the writ, the sheriff cannot remove or demolish the improvements except upon a special order of the court issued after a hearing under Section 10 of Rule 39 of the Rules of Court.

D. Topic Integration:

The case of Padayao v. Villafuerte, Jr. is a landmark application of the simplified land registration rules under Republic Act No. 11573 and Republic v. Pasig Rizal Co., Inc. in the context of possessory actions. The decision directly integrates with the syllabus topic of original registration by clarifying that the "alienable and disposable" character of public land—which is a prerequisite for registration under Section 14, paragraph 1 of Presidential Decree No. 1529—can be provisionally proved in an ordinary civil action using a land classification map (such as Land Classification Map No. 882 certified by the Bureau of Forestry in 1931). By holding that the declassification of public dominion land into patrimonial land occurs by virtue of the land classification map, the Supreme Court protects the possessory rights of public land occupants whose possession began before the formal issuance of a Torrens title. This case harmonizes the administrative functions of the DENR with the judicial policy of protecting prior lawful possessors from arbitrary state evictions, reinforcing the constitutional mandate that no person shall be deprived of property without due process of law.