Cruz vs.

Secretary of DENR
GR. No. 135385
Dec. 6, 2000

FACTS:
Petitioners filed a suit for prohibition and mandamus as citizens and taxpayers, assailing the constitutionality of certain
provisions of RA 8371 (IPRA) on the ground that these amount to an unlawful deprivation of the States ownership over lands of the
public domain as well as minerals and other natural resources therein, in violation of the regalian doctrine embodied in the Constitution.

ISSUE:
Do the provisions of IPRA contravene the Constitution?

HELD:
No, the provisions of IPRA do not contravene the Constitution. Examining the IPRA, there is nothing in the law that grants to
the ICCs/IPs ownership over the natural resources within their ancestral domain. Ownership over the natural resources in the ancestral
domains remains with the State and the rights granted by the IPRA to the ICCs/IPs over the natural resources in their ancestral domains
merely gives them, as owners and occupants of the land on which the resources are found, the right to the small scale utilization of
these resources, and at the same time, a priority in their large scale development and exploitation.
Additionally, ancestral lands and ancestral domains are not part of the lands of the public domain. They are private lands and
belong to the ICCs/IPs by native title, which is a concept of private land title that existed irrespective of any royal grant from the State.
However, the right of ownership and possession by the ICCs/IPs of their ancestral domains is a limited form of ownership and does not
include the right to alienate the same.

Cario vs Insular Government

G.R. No. L-2746
December 6, 1906

FACTS:
Cario went to the Court of Land Registration to petition his inscription as the owner of a 146 hectare land hes been
possessing in the then municipality of Baguio. Mateo only presented possessory information and no other documentation. The State
opposed the petition averring that the land is part of the US military reservation. The CLR ruled in favor of Mateo. The State appealed.
Mateo lost. Mateo averred that a grant should be given to him by reason of immemorial use and occupation.

ISSUE:
Whether or not Mateo is the rightful owner of the land by virtue of his possession of it for some time.

HELD:
No. The statute of limitations did not run against the government. The government is still the absolute owner of the land.
Further, Mateos possession of the land has not been of such a character as to require the presumption of a grant. No one has lived upon
it for many years. It was never used for anything but pasturage of animals, except insignificant portions thereof, and since the
insurrection against Spain it has apparently not been used by the petitioner for any purpose.
While the State has always recognized the right of the occupant to a deed if he proves a possession for a sufficient length of
time, yet it has always insisted that he must make that proof before the proper administrative officers, and obtain from them his deed,
and until he did the State remained the absolute owner.

Grey Alba vs. Dela Cruz

G.R. No. 5246
Sept. 16, 1910

FACTS:
The petitioners are the he only heirs of Doa Segunda Alba Clemente and Honorato Grey. The four petitioners, as co-owners,
on Dec. 18, 1906 sought to have registered a parcel of agricultural land in Bulacan. The petition was accompanied by a plan and
technical description of the said lot. After hearing the court, on Feb. 12, 1908, entered a decree directing that described in the petition
be registered in the names of the 4 petitioners.

ISSUE:
Whether or not,the petitioners did obtain the decree by means of fraud.

HELD:
The subsequent State grant was obtained by Baldomero after the death of the petitioners parents and while he petitioners were
minors. So it is clear that the petitioners honestly believed that the appellee was occupying the said parcels as their lessee at the time
they presented their application for registration. They did not act in bad faith, nor with any fraudulent intent, when they omitted to
include in their application the name of the appellee as one of the occupants of the land. They believed that it was not necessary nor
required that they include in their application the names of their tenants.
Roxas vs. Enriquez
G.R. No. 8539
Dec. 24, 1914

FACTS:
Maria Consuelo applied for titles of 4 parcels of land in 1906. The adjoining owners of the land were informed of such
application, but no one went to question it so they were declared in default. The same application was published in two newspapers.
The City of Manila questioned in court the borders of Parcel A. The Court ordered the correction but none was executed. She sold the
same to Masonic Temple Assoc. The Court granted the motions of the City of Manila and Consuelo.

ISSUE:
Was the court correct in denying the opposition of the heirs of Enriquez?

HELD:
No notice was served to the heirs of Enriquez: Records show that the counsel of Enriquez received a notice. Even if it is
denied by the party, personal notification is not a requirement of the law. Registration is a proceeding in rem and not in personam. It is
the only practical way that allows the Torrens system to fulfill its purpose

Huguete vs. Embudo

GR No. 49554
July 1, 2003

FACTS:
Petitioner filed a complaint for the annulment of deed of sale and partition of land against respondent .
Respondent spouses filed a Motion to Dismiss the complaint on the ground of lack of jurisdiction over the subject matter of the case,
arguing that the action is one for annulment of title and the total assessed value of the subject land was only P15,000.00 which falls
within the exclusive jurisdiction of the MTC.

ISSUE:
WON the civil action is one in which the subject matter is incapable of pecuniary estimation.

HELD:
No. The argument that the present action is one incapable of pecuniary estimation considering that it is for annulment of deed
of sale and partition is not well-taken. What determines the nature of an action as well as which court has jurisdiction over it are the
allegations of the complaint and the character of the relief sought.

Espiritu vs. Valerio

G.R. No. L-18018
Dec. 23, 1976

FACTS:
Valerio filed a case to quiet title against mother and daughter Espiritu who were asserting their adversary rights over said land
and disturbing his possession thereof. Valerio presented a deed of sale from which he acquired the property while the Espiritus allege
that they acquire the same from their deceased father. The Espiritus also presented two deeds of sale to prove that their deceased father
have a legal right over the property which they inherited.

ISSUE:
WON mother and daughter Espiritu have a better right over the property.

HELD:
Apparently, this case concerns the sales of one parcel of land by the same vendor but in favor of two different vendees. If both
allegations of the parties are valid, Espiritu's contention that they have a better right than that the claimed by Valerio would seem to be
meritorious in the light of the facts of the case and the provisions of Article 1544 of the New Civil Code, it not being disputed that the
Deed of Sale in favor of them was registered first. But since the deeds of sale presented by Esiritu are found to be falsified, they have
no legal right to claim the disputed property.

Noblejas vs. Teehankee

G.R. No. L-28790; 23 SCRA 405
April 29, 1968

FACTS:
Sec of Justice Teehankee coursed to Noblejas a letter requiring him to explain in writing why no disciplinary action should be
taken against petitioner for "approving or recommending approval of subdivision, consolidation and consolidated-subdivision plans
covering areas greatly in excess of the areas covered by the original titles." Noblejas answered and apprised the Secretary of Justice
that, as he enjoyed the rank, privileges, emoluments and compensation of a Judge of the Court of First Instance, he could only be
suspended and investigated in the same manner as a Judge of the Courts of First Instance, and, therefore, the papers relative to his case
should be submitted to the Supreme Court.

ISSUE:
WON the Commissioner of Land Registration may only be investigated by the Supreme Court.
HELD:
It is nowhere claimed, much less shown, that the Commissioner of Land Registration is a District Judge, or in fact a member
of the Judiciary.

Ramos vs. Rodriguez

G.R. No. 94033
May 29, 1995

FACTS:
Feliciano Ramos applied for registration of a parcel of land. RTC, acting as a Land Registration Court, rendered a decision
adjudicating the said lot to Ramos. Instead of issuing the said certificate, NLTDRA submitted a report recommending that the
decision made on be set aside since the land involved was already covered by an existing TCT issued in the name of Payatas Estate
Improvement Company.
The Ramos claimed that the said TCT was fraudulent but they failed to present any evidence in support of such allegation. The
RTC, on the other hand, contend that it cannot set aside its decision since it already became final and executory. It added that the proper
remedy of the government was an action for annulment of judgment.

ISSUE:
Whether or not a final and executory decision, after a lapse of more than 15 days, of a Trial Court acting as the Land
Registration Court, can be validly set aside?

RULING:
The Supreme Court held that unlike any ordinary civil actions, the adjudication of land in a cadastral or land registration
proceeding does not become final, in the sense of incontrovertibility, until the expiration of 1 year after the entry of the final decree of
registration.
As long as the final decree has not been entered by the Land Registration Commission (now NLTDRA) and the period of 1
year has not yet elapsed from the date of such entry of the decree, the title is not yet finally adjudicated and the decision of the
registration proceeding continues to be under the control and sound discretion of the court rendering it.

Laburada vs. Land Registration Authority

G.R. No. 101387
March 11, 1998

FACTS:
Sps. Laburada applied for the registration of a lot which was approved by the trial court. Upon motion of petitioners, the trial
court issued an order requiring the LRA to issue the corresponding decree of registration. However, the LRA refused. Hence,
petitioners filed an action for mandamus.

ISSUE:
Whether or not the LRA may be compelled by mandamus to issue a decree of registration if it has evidence that the subject
land may already be included in an existing Torrens certificate of title?

HELD:
NO. It is settled that a land registration court has no jurisdiction to order the registration of land already decreed in the name of
another in an earlier land registration case. A second decree for the same land would be null and void, since the principle behind
original registration is to register a parcel of land only once. Thus, if it is proven that the land which petitioners are seeking to register
has already been registered in 1904 and 1905, the issuance of a decree of registration to petitioners will run counter to said principle.
The issuance of a decree of registration is part of the judicial function of courts and is not a mere ministerial act which may be
compelled through mandamus. It is not legally proper to require the LRA to issue a decree of registration.

Aznar Brothers Realty Company vs. Aying

G.R. No. 144773
May 16, 2005

FACTS:
Aying siblings executed an Extra-Judicial Partition of Real Estate with Deed of Absolute Sale conveying the lot in issue to the
Aznar Brothers Realty Company.
Later, Aznar Brothers Realty Company filed a Petition for Reconstitution of the Original Title since the original title of the lot was
lost during the war. This was granted by the court and the ROD of Lapu-Lapu was directed to issue a reconstituted title in the name of
the Aying Siblings.
Aznar Brothers Realty Company denied that the Ayings are the lawful owners of the land and alleged it had been in actual
possession of subject land as owner thereof by virtue of the extra-judicial partition of real property and deed of absolute sale executed
in its favor; that in fact, it had been paying taxes thereon religiously. The realty company further alleged that they are barred by
prescription to file an action for recovery of property which should be instituted within 4years from discovery of the fraud. It took the
Aying heirs 27years to file their action against the realty company.

ISSUE:
Is the registration of the Extra-Judicial Partition of Real Estate with Deed of Absolute Sale conveying the lot in issue to the
Aznar Brothers Realty Company with the ROD binding and consequently, results in the running of the prescriptive period for
reconveyance?
HELD:
No. The sale of registered property, recorded in the ROD, cannot be considered as registered. Jurisprudence dictates that that
registration of instruments must be done in the proper registry, in order to affect and bind the land and, thus, operate as constructive
notice to the world. In this case, the Extrajudicial Partition of Real Estate with Deed of Absolute Sale was registered under Act No.
3344 and not under Act No. 496, therefore the document cannot be deemed registered. As consequence of non-registration, the 10year
prescriptive period cannot be reckoned from the date of registration of the document under Act. No. 3444 since no constructive notice
to the world was perfected by such registration. The prescriptive period only began to run from the time the Aying heirs had actual
notice of the Extra-Judicial Partition of Real Estate with Deed of Absolute Sale which was not proven by clear and convincing evidence
in this case.

Abrigo vs. De Vera

G.R. No. 154409
June 21, 2004

FACTS:
Villafania sold a house and lot. Unknown, however to Tigno-Salazar and a Cave-Go, Villafania obtained a free patent over the
parcel of land involved.The said free patent was later on cancelled by a TCT. Later, Tigno-Salazar and Cave-Go, sold the house and lot
to the Abrigo. Villafania sold the same house and lot to de Vera. De Vera registered the sale and as a consequence a TCT was issued in
her name.
De Vera filed an action for Forcible Entry and Damages against Spouses Abrigo before the MTC.
Spouses Abrigo filed a case with the RTC for the annulment of documents, injunction, preliminary injunction, restraining order and
damages Villafania.
The RTC rendered the assailed Decision awarding the properties to Abrigo as well as damages. Moreover, Villafania was
ordered to pay [petitioners and private respondent] damages and attorneys fees.

ISSUE:
Who between petitioner-spouses and respondent has a better right to the property.

HELD:
De Vera. The present case involves what in legal contemplation was a double sale. Gloria Villafania first sold the disputed
property to Tigno-Salazar and Cave-Go, from whom petitioners, in turn, derived their right. Subsequently a second sale was executed
by Villafania with Respondent de Vera.

Baranda vs. Gustilo

G.R. No. 81153
Sept. 26, 1988

FACTS:
A petition for reconstitution of title was filed with the CFI involving a parcel of land in the name of Romana Hitalia. The OCT
was cancelled and a new one was issued in the names of petitioners Baranda and Hitalia. The Court issued a writ of possession which
Perez, Gotera and Silao refused to honor on the ground that they also have a TCT over the same lot. The Court found out that was
fraudulently acquired by Perez, Gotera and Susana.
This prompted the petitioners to move for the cancellation of the notice of lis pendens in the new certificates.

ISSUE:
What is the nature of the duty of a Register of Deeds to annotate or annul a notice of lis pendens in a torrens certificate of title.

HELD:
PD 1529 states that "It shall be the duty of the Register of Deeds to immediately register an instrument presented for
registration dealing with real or personal property which complies with all the requisites for registration. If the instrument is not
registrable, he shall forthwith deny registration thereof and inform the presentor of such denial in writing, stating the ground or reasons
therefore, and advising him of his right to appeal by consulta in accordance with Section 117 of this Decree."

Gurbax Singh Pabla and Co vs. Reyes

G.R. No. L-3970
Oct. 29, 1952

FACTS:
The respondents appealed to the court on a decision rendered by the RTC demanding them to surrender owners duplicate of
TCTs so that the contract of lease entered into by the petitioners and the land owner be annotated thereon.

ISSUE:
Whether or not petitioners have a right to have said deeds registered.
RULING:
SC found that the issues raised by Reyes (respondents), were not properly investigated because
Reyes (respondents) did not have the opportunity to present evidence thereon and did not even present copy of their mortgage at the
hearing, and the trial court decided the questions without full and complete investigation.
Ledesma vs. Villaseor
G.R. No. L-18725
March 31, 1965

FACTS:
Villaseor is the special administrator of his deceased fathers estate. He filed a petition with the RTC to prohibit the Register
of Deeds of the same province to register a Deed of Sale made by his father in favor of Ledesma. This was because said Deed of Sale
was allegedly fictitious and the fathers signature was forged. The court then issued a writ of preliminary injunction. Thereafter, the
RTC eventually dismissed the petition and lifted the writ on the ground that Ledesma had not been impleaded as a party-defendant and
he only intervened in the case. 2 days later, Ledesma filed his own petition asking that the Register of Deeds be ordered to register the
aforementioned Deed of Sale on the ground that the earlier case was already dismissed and the writ was dissolved. On the same day, the
court granted the petition without notice to the Register of Deeds and to Villaseor and issued the order for registration. The Register of
Deeds hence cancelled the certificates of title and issued new ones in Ledesmas name. Villaseor moved for reconsideration but was
denied. Hence, present action.

ISSUE:
Was the RTC correct in issuing the order for registration?

RULING:
No. The court had no authority to issue the orders after just 2 days after lifting the injunction and dismissing the civil case
without notice to the Register of Deeds or appellant considering that it was not yet final. The least that the court could have done was to
afford appellant proper notice and hearing as it knew of the pendency of that case and that the relief sought therein was precisely to
prevent registration. For the Register of Deeds, his duty under the circumstances was administrative and ministerial. It does not
contemplate notice and hearing of interested parties such as are required in a judicial proceeding nor carry with it the solemnity and
legal consequences of a court judgment. It can register a document when it is on its face registrable.

Balbin vs. Register of Deeds

G.R. No. L 20611
May 8, 1969

FACTS:
Petitioners presented to the register of deeds a duplicate copy of the registered owners certificate of title and a deed of
donation inter-vivos, requesting that the latter be annotated on the title. The register of deeds denied the requested annotation for being
legally defective or otherwise not sufficient in law. It appears that previously annotated in the memorandum of encumbrances on the
OCT are three separate sales earlier executed. Mainly because these 3 co-owners copies of CTs had not been presented by petitioners,
the register of deeds refused to make the requested annotation. Petitioners referred the matter to the Commissioner of Land
Registration, who upheld the action of the Register of Deeds in a resolution.

ISSUE:
W/N the refusal of the Register of Deeds to make the annotation is proper

HELD:
Yes. There being several copies of the same title in existence, their integrity may be affected if an encumbrance, or an outright
conveyance, is annotated on one copy and not on the others. If different copies were permitted to carry different annotations, the whole
system of Torrens registration would cease to be available.

Benin vs. Tuason

G.R, No. L-26127
June 28, 1974

FACTS:
The plaintiffs alleged that they were the owners and possessors of the three parcels of agricultural lands that they inherited from their
ancestor. After the outbreak of the last World War, after having secured the permission of the plaintiffs, constructed their houses thereon
and paid monthly rentals to plaintiffs. Only defendant J.M. Tuason & Co., Inc. was actually served with summons. The other
defendants were ordered summoned by publication in accordance with Sections 16 and 17 of the Rules of Court. Only defendant J.M.
Tuason & Co., Inc. appeared. The other defendants were all declared in default.

HELD:
The court sited the Santiago case which states that, (T)he mere fact that appellants herein were not personally notified of the
registration proceedings that resulted in a decree of registration of title in favor of the Tuasons in 1914 does not constitute in itself a
case of fraud that would invalidate the decree. The registration proceedings, as proceedings in rem, operate as against the whole world
and the decree issued therein is conclusive.
Republic vs. Umali
G.R. No. 80687
April 10, 1989

FACTS:
A land was assigned to Cenizals by the lands original owner, Bobadilla who purchased the same from the government. The
land went through several transfers until its registered owners became Pulido, Rosalina, Enrique, Naval, and Miclat. The government
asked for the return of the property after discovering that the sale was tainted with forgery.

ISSUE:
Whether or not the land can be reverted back to the government after discovering such defect on the deed of sale.

RULING:
No. The present possessors and owners are innocent transferees for value. They all believed that the certificate of title that fell
into their hands are free from all encumbrances, except as those indicated on the face of the certificate, and that the certificate is clean
and not tainted with fraud.

Grande vs. CA
G.R. No. L-17652
June 30, 1962

FACTS:
The Grandes are owners of a parcel of land. A gradual accretion took place due to the action of the current of the river, and an
alluvial deposit was added to the registered area. The Grandes filed an action for quieting of title against the Calalungs, stating that they
were in peaceful and continuous possession of the land created by the alluvial deposit. The Calalungs, however, stated that they were
the rightful owners since prior to 1933.

ISSUE:
Whether or not the alluvium deposited land automatically belongs to the riparian owners?

HELD:
Art. 457 dictates that alluvium deposits on land belong to the owners of the adjacent land. However, this does not ipso jure
become theirs merely believing that said land have become imprescriptible. The land of the Grandes only specifies a specific portion, of
which the alluvial deposits are not included, and are thus, subject to acquisition by prescription. Since the Calalungs proved that they
have been in possession of the land since 1934 via two credible witnesses, as opposed to the Grandes single witness who claims that
the Calalungs only entered the land in 1948, the Calalungs have been held to have acquired the land created by the alluvial deposits by
prescription. This is because the possession took place in 1934, when the law to be followed was Act 190, and not the New Civil Code,
which only took effect in 1950.

Director of Lands vs. Santiago

G.R. No. L-41278
April 15, 1988

FACTS:
An application for land registration was filed by respondent. On the date of the initial hearing, neither petitioner nor his
counsel was present; an order of general default was issued by the respondent Judge on the same date. Thereafter, petitioner filed a
Motion for New Trial on the grounds that the failure of his counsel to appear at the initial hearing was excusable and that the decision
was contrary to facts and to law. The motion was however denied.

ISSUE:
WON respondent Judge Santiago erred in decreeing the following orders and decisions:

HELD:
The lower court gravely abused its discretion when it granted the respondent corporations application for registration, without
sufficient proof that the applicant possessed an imperfect and incomplete title that is registrable under Sec. 48, par. b, of
Commonwealth Act 141, as amended by Republic Act 6236, otherwise known as the Public Land Act.

Roman Catholic Apostolic Administrator of Davao vs. LRC

G.R. No. L-8451
Dec. 20, 1957

FACTS:
Rodis, a Filipino citizen, executed a deed of sale of a parcel of land in favor of the petitioner, a corporation sole organized and
existing in accordance with Philippine Laws, with Msgr. Clovis Thibault, a Canadian citizen, as actual incumbent.
The LRC ruled that the vendee was not qualified to acquire private lands in the Philippines in the absence of proof that at least
60 per centum of the capital, property, or assets of the Roman Catholic Apostolic Administrator of Davao, Inc., was actually owned or
controlled by Filipino citizens, there being no question that the present incumbent of the corporation sole was a Canadian citizen.

ISSUE:
W/N Roman is qualified to acquire private agricultural lands in the Philippines.
HELD:
Yes. Register of Deeds of the City of Davao is ordered to register the deed of sale. A corporation sole consists of one person
only, and his successors (who will always be one at a time), in some particular station, who are incorporated by law in order to give
them some legal capacities and advantages, particularly that of perpetuity, which in their natural persons they could not have had.

Republic vs. IAC and Roman Catholic Bishop of Lucena

Gr. No. 75042
Nov. 29, 1988

FACTS:
Petitioner, represented by Msgr. Sanchez, applicant vs. the Director of Lands and the Director, Bureau of Forest Development
Granted to Roman Catholic Bishop of Lucena - Evaluating the applicant's submitted proofs, the court a quo concluded, on the basis of
acquisitive prescription at the very least, that the former had adequately shown title to the parcels of land being claimed.

ISSUE:
Whether or not a corporation sole should be treated as an ordinary private corporation, for purpose of the application of Art.
XIV, Sec. 11 of the 1973 Constitution.

HELD
A corporation sole is a special form of corporation usually associated with the clergy.
A corporation sole consists of one person only, and his successors (who will always be one at a time).

Republic vs. Court of Appeals and Naguit

G.R. No. 144057
Jan. 17, 2005

FACTS:
Naguit filed a petition for registration of title of a parcel of land. The application sought a judicial confirmation of imperfect
title over the land. The public prosecutor, appearing for the government, and Angeles opposed the petition. The court issued an order of
general default against the whole world except as to Angeles and the government.

ISSUE:
Whether or not it is necessary under the Property Registration Decree that the subject land be first classified as alienable and
disposable before the applicants possession under a bona fide claim of ownership could even start.

HELD:
Under Section 14 of the Property Registration Decree, there are three obvious requisites for the filing of an application for
registration of title under Section 14(1) that the property in question is alienable and disposable land of the public domain; that the
applicants by themselves or through their predecessors-in-interest have been in open, continuous, exclusive and notorious possession
and occupation, and; that such possession is under a bona fide claim of ownership since June 12, 1945 or earlier. In this case, the 3
requisites for the filing of registration of title under Section 14(1) had been met by Naguit.

Lacamen vs. Laruan

G.R. No. L-27088
July 31, 1975

FACTS:
Laruan executed a deed of sale in favor of Lacamen which was duly notarized. Immediately after the sale, Laruan delivered
the certificate of title to Lacamen. Thereupon, Lacamen entered in possession and occupancy of the land, introduced improvements
therein, without securing the corresponding certificate of title. The document was also not approved by the Director of the Bureau of
Non-Christian Tribes whose approval is necessary in order for the Deed to be valid. This rule bounds the contracting parties
considering that they belong to the illiterate non-Christians. Later on, after the death of Laruan, his heirs discovered that Laruans heirs
were able to obtain a new owners certificate of title. Hence, they sued Laruans heirs for reconveyance. The Trial Court rendered a
decision in favor of the heirs of Laruan whose decision was affirmed by the CA.

ISSUE:
WON estoppel by laches applies.
HELD:
Laruans sale of the subject lot to Lacamen could have been valid were it not for the sole fact that it lacked the approval of the
Bureau of Non-Christian Tribes considering that there was impressed upon its face full faith and credit after it was notarized. However,
notwithstanding the invalidity of the sale, the fact that when the Lacamens succeeded to the estate of their father, the Laruans kept
silent, never claiming that the lot is their own. Even granting that no prescription lies against their fathers record title, their inaction for
almost 30 years commands the imposition of laches. Hence, the Lacamens were declared as the owners of the land.
Republic vs. CA and Tancinco
G.R. No. L-61647
Oct. 12, 1984

FACTS:
The respondents (Tancincos) were registered owners of a parcel of land bordering Maycauayan and Bocaue Rivers. They filed
an application for the registration of three lots adjacent to their fishpond, but because of the recommendation of the Commissioner, they
only pushed for the registration of two. The RTC and CA granted the petition despite the opposition of the Bureau of Lands.

ISSUE:
Whether accretion took place.

RULING:
No. Alluvion must be the exclusive work of nature. The lots in question were portions of the bed of the Meycauayan River and
are therefore classified as public property.

Laurel vs. Garcia

G.R. No. 92013
July 25, 1990

FACTS:
Petitioners seek to stop the Philippine Government to sell the Roppongi Property, which is located in Japan. It is one of the
properties given by the Japanese Government as reparations for damage done by the latter to the former during the war.
Petitioner argues that under Philippine Law, the subject property is property of public dominion. As such, it is outside the
commerce of men. Therefore, it cannot be alienated.
Respondents aver that Japanese Law, and not Philippine Law, shall apply to the case because the property is located in Japan.
They posit that the principle of lex situs applies.

ISSUES:
WON the subject property cannot be alienated.

HELD:
Yes Under Philippine Law, there can be no doubt that it is of public dominion unless it is convincingly shown that the property
has become patrimonial. This, the respondents have failed to do. As property of public dominion, the Roppongi lot is outside the
commerce of man. It cannot be alienated.