Title is void if land inalienable; cancelled even if innocent purchaser for value

It is well-settled that a certificate of title is void when it covers property of public domain classified as forest or timber and mineral lands. Any title issued on non-disposable lots even in the hands of an alleged innocent purchaser for value, shall be cancelled. (G.R. Nos. L-31666, April 30, 1979)

Where the lower court, in granting titles to the land in dispute, counted the period of possession of private respondents before the same were released as forest lands for disposition, such release is tantamount to qualifying the latter to a grant on said lands while they were still non-disposable. Thus, even assuming that the transferees are innocent purchasers for value, their titles to said lands derived from the titles of private respondents which were not validly issued as they cover lands still a part of the public domain, may be cancelled. (G.R. No. L-40402, March 16, 1987)

To complete the picture, reference may be made to the learned and scholarly opinion of Justice Sanchez in Director of Forestry v. Muñoz, a 1968 decision. After a review of Spanish legislation, he summarized the present state of the law thus:

If a Spanish title covering forest land is found to be invalid, that land is public forest land, is part of the public domain, and cannot be appropriated. Before private interests have intervened, the government may decide for i what Portions of the public domain shall be set aside and reserved as forest land. Possession of forest lands, however long, cannot ripen into private ownership.

He reiterated the basic state objective on the matter in clear and penetrating language:

"The view this Court takes of the cages at bar is but in adherence to public policy that should be followed with respect to forest lands. many have written much, and many more have spoken, and quite often, above the pressing need for forest preservation, conservation. protection, development and reforestation. Not without justification For, forests constitute a vital segment of any country's natural resources. It is of common knowledge by now that absence of the necessary green cover on our lands produces a number Of adverse or ill effects of serious proportions. Without the trees, watersheds dry up; rivers and lakes which they supply are emptied of their contents. The fish disappears. Denuded areas become dust bowls. As waterfalls cease to function, so will hydroelectric plants. With the rains, the fertile topsoil is washed away; geological erosion results. With erosion come the dreaded floods that wreak havoc and destruction to property — crops, livestock, houses and highways — not to mention precious human lives..."