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ITURALDE VS FALCASANTOS. Issue?

Whether or not the filing of public land application approved by the Bureau of Lands is equivalent to declaration that said land was no longer part of the public domain. Ruling? A positive act of the government is needed to declassify a forest land into alienable or disposable land for agricultural or other purposes. " And the rule is "Possession of forest lands, however long, cannot ripen into private ownership."

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