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Jun 16, 2008

G.R. No. 50464, Jan. 29, 1990


Sunbeam Convenience Foods, Inc. is the recipient of a Sales Patent issued by the Bureau of Lands over two parcels of land in Bataan. An OCT was thereby issued. The Solicitor-General filed an action for reversion on the ground that the lots were forest lands and therefore inalienable.

CA ruled, upholding the Solicitor-General's contention.


  • Whether or not land is alienable


The SC affirmed.

Our adherence to the Regalian Doctrine subjects all agricultural, timber, and mineral lands to the dominion of the State. Thus, before any land may be declassified from the forest group and converted into alienable or disposable land for agricultural purposes, there must be a positive act from the Government. Even rules on the confirmation of imperfect titles do not apply unless and until the land classified as forest land is released in an official proclamation to that effect so that it may form part of the disposable agricultural lands of the public domain.

The mere fact that a title was issued by the Director of Lands does not confer any validity on such title if the property covered by the title or patent is part of the public forest.


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