Dela Cruz v CA

Facts:

The land involves a residential lot in San Jose, Bulacan, Bulacan. Eugenio Dela Cruz claims to be the owner and actual possessor of the lot for more than 30 yrs since Sept. 1987.

In Oct 1959, Dela Cruz contracted a loan from the parents of Christina Villanueva (who was claiming that she was a successor-in-interest after she purchased the lot from the Ramos brothers) and Dela Cruz mortgaged the land as security. In 1973, the land became subject of application under the Land Registration Act. This was done by the Ramos brothers. But Dela Cruz opposed the application for registration. The application was denied because the land still remained part of the forest reserve, hence, it is inalienable.

Afterwards, the brothers pursued the reclassification successfully and were granted ownership. Dela Cruz did not know of this instance so he was surprised to learn that the ownership was bestowed to the Ramos brothers. De La Cruz filed for reconveyance but it was dismissed.

Dela Cruz went to the CA, claiming that his uncle gave the land to his mother after having purchased it from Cecilio Espiritu in 1930. But, the CA also affirmed the RTC.

Dela Cruz now goes to SC for review.

Issue:

Is Dela Cruz vested with a better right over the residential lot?

Held:

No. Dela Cruz possessed and occupied the land after it has been declared by Gov’t as part of the forest zone. The land remained part of the forest reserve until such time it was reclassified into alienable/disposable by the Ramos brothers. Even if Dela Cruz cultivated and fenced the land, it was still a forest land.

Forest lands cannot be acquired by prescription. Therefore, possession of the lot could never ripen into ownership.

Estoppel will also not apply in this case because Dela Cruz did not possess the capacity to encumber the land at the time the land was still classified as forest.

SC affirms.