Case Brief: RP-BFD vs. IAC

G.R. No. 69138 May 19, 1992

REPUBLIC OF THE PHILIPPINES (Bureau of Forest Development), petitioner,
INTERMEDIATE APPELLATE COURT (First Civil Cases Division) and HILARIO P. RAMA, respondents.


Logronio, as OIC of Bohol Reforestation Project of Bureau of Forest Development (BFD) bulldozed portions of land which he believed to be forest lands, occupied the same, and planted trees. Thereafter, Rama filed a complaint for recovery of possession and ownership, alleging that he is the owner and possessor of lands occupied by Logronio, who then claimed that the forest lands were part of his lawful performance of his duties as OIC. Logronio also alleged that the lands were never released by government as alienable and disposable. He filed for the nullification of any titles concerning the land.



Whether or not Rama’s title over the land is valid



No, it is not valid. Considering that the subject parcel of land is forest land, the patent and original certificate of title covering the subject parcel issued to Rama did not confer any validity to his possession or claim of ownership.  The titles are void ab initio.  The appellate court’s ruling as regards the unregistered parcel of land which is to the effect that Rama is also entitled to necessary expenses with right of retention until reimbursed of the necessary expenses must be reversed. His title over the forest land is null and void for the same reasons.


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