natres transcription - atty. batacan (la)

8/12/2019 NatRes Transcription - Atty. Batacan (LA)

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NATURAL RESOURCESATTY. BATACAN (SY 2013-14) | CUTIE NOTES

Natural Resources

Lectures of Atty. Batacan

Constitutional Provision on Natural Resources

Where do we find the duty to conserve and preserve

our natural resources and what do we understand bythe term natural resources?

Natural resources is defined as material objects

of economic value and utility to man produced by

nature. Anything that is valuable to man and produced

by nature is considered as natural resources and will

constitute the patrimony of the nation, the heritage of

the nation.

The duty to preserve, conserve and develop our natural

resources is found in the preamble.

Preamble of 1987 Constitution

We, the sovereign Filipino people, imploring the aid

of Almighty God, in order to build a just and

humane society and establish a Government that

shall embody our ideals and aspirations, promote

the common good, conserve and develop our

patrimony, and secure to ourselves and our

posterity the blessings of independence and

democracy under the rule of law and a regime of

truth, justice, freedom, love, equality, and peace,

do ordain and promulgate this Constitution.

The duty to conserve and preserve... Wala ka

masyadong makita nohexcept on the preamble. But for

purposes of our subject, Natural Resources, we would

be concentrating on the provisions of our 1987

Constitution (Article 12 on National Patrimony.)

What is the concept of jura regalia in the context of

Constitutional Law? What is the Regalian doctrine?

The Regaliandoctrine reserves to the State all

natural wealth that may be found in the bowels of the

earth even if the land where the discovery is made be

private.(Republic vs. Court of Appeals 160 SCRA 228)

Natural wealth is found in the bowels of the

Earth, within the territorial jurisdiction of the

Philippines. This concept is embodied in Section 2,

Article XII of the 1987 Constitution.

SECTION 2.All lands of the public domain, waters,

minerals, coal, petroleum, and other mineral oils

all forces of potential energy, fisheries, forests o

timber, wildlife, flora and fauna, and other natura

resources are owned by the State. With the

exception of agricultural lands, all other natura

resources shall not be alienated. The exploration

development, and utilization of natural resources

shall be under the full control and supervision ofthe State. The State may directly undertake such

activities, or it may enter into co-production, joint

venture, or production-sharing agreements with

Filipino citizens, or corporations or associations at

least sixty per centum of whose capital is owned by

such citizens. Such agreements may be for a period

not exceeding twenty-five years, renewable for no

more than twenty-five years, and under such terms

and conditions as may be provided by law. In cases

of water rights for irrigation, water supply, fisheries

or industrial uses other than the development o

water power, beneficial use may be the measure

and limit of the grant.

The State shall protect the nation's marine wealth

in its archipelagic waters, territorial sea, and

exclusive economic zone, and reserve its use and

enjoyment exclusively to Filipino citizens.

The Congress may, by law, allow small-scale

utilization of natural resources by Filipino citizens

as well as cooperative fish farming, with priority to

subsistence fishermen and fishworkers in riverslakes, bays, and lagoons.

The President may enter into agreements with

foreign-owned corporations involving eithe

technical of financial assistance for large-scale

exploration, development, and utilization o

minerals, petroleum, and other mineral oils

according to the general terms and conditions

provided by law, based on real contributions to the

economic growth and general welfare of the

country. In such agreements, the State shalpromote the development and use of local scientifi

and technical resources.

All lands of the public domain:

1. Agricultural land

2. Mineral land

3. Timberland or Forest land

4. National parks


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Of these four, only agricultural lands are

alienable. The rest are inalienable.

Again, what are under natural resources:

"All lands of the public domain, waters, minerals, coal,

petroleum, and other mineral oils, all forces of potential

energy, fisheries, forests or timber, wildlife, flora and

fauna, and other natural resources."

Ano ibig sabihin ng Regal? Kingly. Nung araw

kasi.. Kapanahunan ng mga kings. Ngayon, instead of

this property belonging to the king, hindi naman tayo

monarchy, they belong to the State. Now, the

ownership of the State of all these natural resources

carries with it the power or authority to dispose. When

you say that the state is sovereign, it means that the

state can do anything under the sun. Pero diba

nakakatakot yun if they can do anything? So ano ang

ginawa ng Constitution? It imposed limitations. The

State itself curtailed its powers as sovereign. So what I

am trying to say here? The power to own carries with it

the power to dispose.

The State can dispose its property under any

circumstances, anytime that it wants, without

conditions at all. But as I've said, the Constitution laid

down some limitations. What are these limitations?

Nasa section 2 pa rin.

1.

"With the exception of agricultural lands, all

other natural resources shall not bealienated."

Only agricultural lands of the public

land may be alienated. In other words, the State

cannot alienate mineral lands, forest lands and

national parks.

2.

"The exploration, development, and utilization

of natural resources shall be under the full

control and supervision of the State."

The State may..

1.

Directly undertake such activities (e.g. Ang

State mismo ang magmimina); or

2.

Enter into co-production, joint venture, or

production-sharing agreements (e.g. The

State may enter into contracts to exploit or

develop our natural resources. These

agreements are limited to Filipino citizens

and Filipino-owned corporations. When we

say Filipino-owned corporations, we mean

majority of the shares are owned by the

Filipinos. Majority means at least 60%

Why? In order to ensure that the Filipinos

are in control of the corporations.)

The Supreme Court said, "The

exploitation of the nation of the naturaresources of the Filipinos is one of the hallmarks

of our national integrity. If our natura

resources, which is the material basis of ou

nation's existence, is placed in the hands o

aliens over whom the Philippine Governmen

does not have complete control, the Filipinos

may soon find themselves deprived of thei

patrimony and living as it were, in a house tha

no longer belongs to them." (Republic vs

Quasha 46 SCRA 160)

So if you allow foreigners to acquire lands of the

public domains, they have money diba... Tayo

nga walang pera, so ano?

3. "Such agreements may be for a period not

exceeding twenty-five years, renewable for

not more than twenty-five years, and

under such terms and conditions as may be

provided by law."

All agreements shall not exceed 25

years but renewable every 25 years. There is nosuch thing as perpetual agreement. The

Constitution itself limits it to 25 years. But it is

renewable for another 25 years. If you may ask

bakit 25 25 lang? If you add the two, total 50

Why 50 years? Because that is the juridical life

of a corporation. The 25 year limit is not

applicable to water rights.

The general rule is agreements shall not exceed

25 years but renewable for another 25 years.

Exception: Not applicable for water rights(Water rights for irrigation, for water supply

fisheries, or industrial uses)

The beneficial use is the limit or measure of the

grant.

"In cases of water rights for irrigation, wate

supply, fisheries, or industrial uses other than

the development of water power, beneficial use

may be the measure and limit of the grant."


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4. "The State shall protect the nation's marine

wealth in its archipelagic waters, territorial

sea, and exclusive economic zone, and reserve

its use and enjoyment exclusively to Filipino

citizens."

The use and enjoyment of the marinewealth, of the archipelagic waters, territorial

sea, and exclusive economic zone shall be

reserved for Filipino citizens. Filipino citizens

means Filipino natural persons. This is according

to the opinion of Fr. Bernas. So, this suggestsna

100% Filipino or if corporation, 100% of the

stocks are owned by Filipinos.

5. "The Congress may, by law, allow small-

scale utilization of natural resources by Filipino

citizens, as well as cooperative fish farming,

with priority to subsistence fishermen and

fishworkers in rivers, lakes, bays, and

lagoons."

The utilization of natural resources may

be allowed on small-scales. The term "small-

scale" refers to single proprietorship. If you

allow corporations to utilize the natural

resources, then you defeat the purpose of the

law.

Summary 5 Rules:1. Only agricultural lands are alienable.

2. The exploration, development and utilization of

natural resources belong to the state

3. Agreements of the State and corporations shall not

exceed for 25 years but may be renewed for another 25

years

4. The use and enjoyment of the marine wealth, of the

archipelagic waters, territorial sea, exclusive economic

zone shall be reserved for Filipino citizens.

5. The utilization of natural resources may be allowed

on small-scales.

Sec. 3 talks about Rules on Disposition.

SECTION 3. Lands of the public domain are

classified into agricultural, forest or timber, mineral

lands, and national parks. Agricultural lands of the

public domain may be further classified by law

according to the uses which they may be devoted.

Alienable lands of the public domain shall be

limited to agricultural lands. Private corporations o

associations may not hold such alienable lands of

the public domain except by lease, for a period no

exceeding twenty-five years, renewable for no

more than twenty-five years, and not to exceed one

thousand hectares in area. Citizens of the

Philippines may lease not more than five hundred

hectares, or acquire not more than twelve hectaresthereof by purchase, homestead, or grant.

Taking into account the requirements o

conservation, ecology, and development, and

subject to the requirements of agrarian reform, the

Congress shall determine, by law, the size of land

of the public domain which may be acquired

developed, held, or leased and the condition

therefor.

Ano yung rules?

1.

Lands of the public domain are classified into

agricultural, forest or timber, mineral lands,

and national parks. Agricultural lands of the

public domain may be further classified by law

according to the uses which they may be

devoted. Alienable lands of the public domain

shall be limited to agricultural lands.

Only agricultural lands of the public

domain may be alienated. So, how about the

rest? How can they be utilized, exploited and

developed? Sabi ko kaninathere are four ways.

The modes of exploitation of all the lands of the

public domain that are inalienable.

1.

Direct activity

2.

Co-production

3.

Joint venture

4.

Production-sharing

2. Only qualified individuals may acquire alienable

lands of the public domain.

By qualified individuals, we mean

natural Filipinos. How about corporations? They

are not allowed and qualified to acquire

agricultural land but they can hold. There's a big

difference between the terms acquire and hold

When we say "acquire", ownership is

transferred to another individual. When we say

"hold," the ownership is retained by the State

but possession is given to the lessee. Therefore


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when we say "hold," we mean lease. There is a

lease contract.

What is the reason? Bakit hindi pwede ang

corporation mag-acquire ng alienable lands of

the public domain? Bakit disqualified sila?

In the case of Lauson (118 SCRA 492),the Supreme Court said that the purpose of this

Constitutional provision is to equitably diffuse

land ownership or to encourage owner to be

keeper *** and take a family-sized farm and

therefore to discourage large land holdings by

corporations.

So, in order to equitably diffuse land

ownership. Nung araw kasi, ang mga

corporations, ang laki-laki ng kanilang land

holdings. In order to prevent the same

occurrence at the present, sa ating

Constitution, bawal na. Only Filipino citizens

may acquire alienable lands of the public

domain.

In the case of Republic vs. Villanueva

(114 SCRA 875), the Court said the "prohibition

was gained against undue exploitation of our

natural resources by large corporations. "

3. Filipinos are allowed to acquire not more than

12 hectares. For leases, corporation can only leaseup to 1,000 hectares.

"xxx not to exceed one thousand hectares in

area. Citizens of the Philippines may lease not

more than five hundred hectares, or acquire not

more than twelve hectares thereof by purchase,

homestead, or grant."

The Court ruled in its discretion of the Congress

to open public lands for lease for or acquisition ***.

Summary:

1. Only agricultural lands are alienable

2. Only qualified individuals may acquire alienable lands

of the public domain. Corporations cannot acquire but

they can hold through lease.

3. Filipinos can acquire only up to 12 hectares while

corporations can lease only up to 1,000 hectares.

---- END OF FIRST EXAM ----


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1903: The Public Land Law permitted the corporations,

regardless of the nationality of the persons owning

them, to purchase lands of the public domain.

In 1919 came Act. No. 2874. After 62 years from the

Public Land Law. It limited the exploitation of

agricultural lands to Filipinos as well as Americans andcitizens of other countries which give reciprocity to the

Philippines.

Then came CA 141. It became effective on December 1,

1936. It merely re-enacted Act. No. 2874 with respect to

the modification with the nationality provision of the

1935 Constitution. The 1935 Constitution preceded this

law because this was enacted about a year after. It

limits the disposition of lands to agricultural lands only.

Wala nang ibang class unlike before na kahit na ano

pwede. So, under CA 141, agricultural lands are furtherclassified into two (please check).

Also, we have Act. No. 3013 which covers the

disposition of patrimonial property of the government.

Another law Act. No. 1123 and CA 32 as amended by CA

316. These laws cover the disposition of mineral (?)

lands.

Another law is the Revised Administrative Law which

covers the disposition of timber lands. Now, we have

the Revised Forestry Law or PD 701. Dati, CA 542

amending the Revised Administrative Law. Yan ang law

governing the disposition of the timber lands. At

present, PD 705 which covers the administration of

timber lands and national parks.

We also have CA 137. This is an old law. It's the Mining

Act. We also have the Coal Act - RA 3719. Also, the

Petroleum Act or RA 387.

Then, RA 7160 also known as the Local Government

Code of 1991 where the local government units has alimited power to re-classify agricultural lands of the

public domain within its territorial jurisdiction.

What office is mandated to control, develop or utilize

our natural resources?

As provided under Title 14, Sections 122 of EO 292 also

known as the Administrative Code of 1987 (ordered

during the time of Corazon Aquino.)...

In the case of Custodio Mari vs. Sec. of

Agriculture (92 Phil 410), the Supreme Court

said "The Administration and distribution of

public lands is committed by law to the Directo

of Lands primarily, and ultimately to the

Secretary of the Department of Agriculture and

Natural Resources. In the exercise of such

power they have to determine the conflictingclaims of applicants and occupants of

disposable lands of the public domain."

Who has the jurisdiction to adjudicate conflicting lands

concerning disposable lands of the public domain?

DENR. So, it is the DENR or Directors of Land which can

adjudicate claims regarding disposable lands of the

public domain.

Is the grant of power and duty to the DENR operate to

divest the ordinary courts of their jurisdiction to

adjudicate conflicting claims? Example, conflicts in

possession. To say it differently, the law vests DENR to

adjudicate conflicting claims. Does it follow that the

regular courts have lost their jurisdiction?

The Supreme Court, in the case of Pitargue vs

Sorilla (92 Phil 65), said "The vesting of the

Lands Department with authority to administer

dispose, and alienate public lands, therefore

must not be understood as depriving the othe

branches of the Government of the exercise o

their respective functions or powers thereon

such as the authority to stop disorders and quelbreaches of the peace by the police, and the

authority on the part of the courts to take

jurisdiction over possessory actions arising

therefrom not involving, directly or indirectly

alienation and disposition."

What the SC is saying is that the power of the DENR

does not divest regular courts their duty to try and hea

cases involving cases with subject matter about

possession?

What is the jurisdiction of the DENR with respect to

disposition and alienation of the lands of the public

domain?

If there are two applicants over a single

property or a piece of land, then sa DENR because i

involves alienation and disposition. That's the

jurisdiction of DENR.

But when the issue involves breaches of peace

such as possession. Sabi ng isa na siya ang dapat na


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possessor, sabi naman ng isa no. So, in issues of

ejectment. When we say possession, it does not refer to

ownership. It does not mean who has rights to own the

land for purposes of alienation. Meaning, the State does

not award this property.

To make it simple. When the issue involves alienation

and disposition of public lands, it is the DENR. If itinvolves merely possession and breaches of peace, it

must be the ordinary courts.

When a court adjudicates the issue in favor of

one party, it does not declare who is the owner of the

property. It merely declares who is entitled for the

possession of the property. What I'm trying to say is

that if there is a disposition of ownership in favor of one

of the applicants, then it must the DENR ang may

jurisdiction.

What are the forms of concession of agricultural lands

under CA 141?

1.

Homestead

2.

Lease

3.

Confirmation of Imperfect Title

a.

Judicial legalization

b.

Administrative legalization

4.

Sale

We're going to discuss this one by one.

Let's go to Homestead. What is the concept ofHomestead?

By homestead is meant the home, the house and the

adjoining land where the head of the family dwells. It

can also be a home farm, the fixed residence of the

head of the family, with land buildings surrounding the

main house.

So it is the land plus the building = Homestead

But under CA 141, Homestead is a home of

disposition of alienable lands of the public domain. It isa mode of a transfer of ownership of the disposable

lands of the public domains.

How can you own an alienable and disposable lands of

the public domain?

You apply for a homestead. If you are granted a

homestead, then you will now own the land.

What is the purpose of the Homestead?

The Supreme Court in the case if Jocson vs

Soriano (45 Phil 375), "To give the homesteade

a place to live with his family so that he may

become a happy citizen and a useful member o

our society."

Sabi nila, the root cause of insurgency is ou

poverty. So, the solution there is to eradicate povertyOne way of eradicating poverty is to provide

employment. One way of providing employment is to

give our lands. Bigyan ng lupa ang mga tao na yan para

mawala sa kanilang isipan ang kanilang problema. So,

useful in the society na. That's the purpose.

Cross reference pala is Article 152 of the Family

Code on Family Home. It is the dwelling house and the

land on which it is situated. Family home is where the

family resides. It is the house, as well as the land. It is

exempt from execution for as long as it is constituted as

body home.

Is homestead exempt from execution? Hindi pa siya

pwede i-execute?

Cross reference nito is Section 13a Rule 39 of the Rules

of Court including Article 157 of the Family Code.

If you look at Rule 39 (Section 13a), it talks

about homestead as exempt from execution. Hindi yan

ang ibig sabihin ng homestead under CA 141. The

homestead under CA 141 is not the homestead

mentioned under Section 3, par. 3. So what does itmean for homestead under Section13? It means fo

purposes of execution, it means the dwelling house o

the judgement debtor resides and the land in

connection therewith. Kaya sinasabi ko, cross-reference

natin is Articles 152 and 157 of the Family Code kas

halos magkaparehas sila.

Going back to the question, is homestead exempt from

execution?

The answer is yes but under Section 13 paragraph m

Rule 39, not under Section paragraph a.(Properties specially exempted by law. But no

article or species of property mentioned in this

section shall be exempt from execution issued

upon a judgment recovered for its price or upon

a judgment of foreclosure of a mortgage

thereon.)

If you read CA 141, the homestead is exempt from

execution. There is a limitation within the 5 yea


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prohibitory period. Within that time, the homestead

under CA 141, is exempt from execution.

In the cases of Beach vs. Pacific (49 Phil 385)

and Francisco vs. Parsons Hardware (67 Phil 234), the

Supreme Court said that the homestead cannot be

made liable for the satisfaction of any debt contracted

before the expiration of the 5-year period from theissuance of the patent.

If may judgment debtor and writ of execution,

the court will order the sheriff to levy on your property.

Pwede bang i-levy ang homestead sa inyong debt? No.

Not within the prohibitory period. What if kusa mong

ibinigay? Dacion en pago. You pay your debt and your

dacion is your property. So, is it still covered under the

prohibition? Yes because the Supreme Court in the

Beach and Francisco cases, if you allow that to happen,

you are circumventing the law.

Basis: Section 118 of CA 141

What would happen after the 5-year prohibitory

period? Is homestead still under the exemption from

execution?

The answer is yes but not under CA 141 but under the

provisions of the Family Code under Article 152 for as

long as the homestead is also constituted as a family

home.

If within the 5-year prohibitory period, whether

voluntary or involuntary, sale, encumbrance anddisposition of homestead is exempt under Section 13m

of Rule 39 and Section 118 of CA 141.

If made after the expiration of the prohibitory

period, is it still exempt from execution? Yes but this

time, under Article 152 of the Family Code.

What is the extent of the exemption from execution?

...When the judgment is rendered to recover --- upon a

judgment for mortgage or foreclosure. Niutang ka,

ginawa mong collateral. Can you still claim forexemption? No. That's an exemption.

If niutang ka, di ka nakabayad, di pwede i-

execute ang homestead or family home for the

settlement of the debt. Pero if nangutang ka sa bangko,

then ginawa mong collateral, you cannot claim "exempt

ko from execution."

Hindi kasali ang value in excess of Php 300,000

in urban and Php 200,000 in rural areas. So, it's

exemption is only up to Php 300,000 or 200,000.So, 18

years of age, does not own more than 24 hectares of

land. As to natural persons not allowed to acquire

homestead. As to married woman, generally, no

allowed. It must be the husband. As a general rule, the

married woman is not allowed to apply for homesteadunless she is living separately from the husband and not

dependent upon him for support. Another exception is

when her husband is insane or physically incapacitated

to work and third when her husband is in prison serving

a term of such duration as to --- him from complying

with the requirements of the law regarding the --- o

the land. So these are the instances where a married

woman may be allowed for a homestead.

What is the maximum allowed under CA 141?Not more than 24 hectares. So up to 24 hectares only.

think this has been modified by the 1987 Constitution

where the maximum area is only 12 hectares. As to the

issue whether or not a qualified person may be

qualified for more than 2 homesteads, as a general rule

no. The privilege is granted to a homesteader by Act

No. 926 to acquire additional homestead but there are

exceptions.

As a general rule, only one homestead i

allowed. As an exception: where homestead is acquired

prior to the approval of CA 146, provided that the oldhomestead plus the new homestead do not exceed 24

hectares. Again, this is modified by the 1987

Constitution. Second, when old homestead plus new

homestead are located adjacent in the same

municipality. Magkatabi sa isang municipality. And the

patent for the old homestead has not yet been issued

prior to the entry to the news homestead. Ibig sabihin

hindi pa na-issuehan ng patent. Homestead entry

meaning you are allowed to possess the land.

By the way, you read the case of Republic of CA(129 S 331).

What is the procedure?

You have to apply a formal application in writing. Comes

the approval of the application. After, entry is allowed

When entry is allowed, you are given time within which

to cultivate the land. After that, there is a hearing in

order to receive evidence of compliance of the

requirements of cultivation. After submitting the


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evidence, survey will follow if plan is --- and eventually

the plan is approved. After the approval of the plan, the

grant of the patent.

If you are granted a patent, you register it in

accordance to provisions PD 1529 or the Property

Registration Decree to come under the protection of

Torrens System of registration in the Philippines.

Now, what is the nature of the right of

possession of a homestead applicant? After your

application is approved, you are allowed entry. Diba?

This is the ideal procedure but actually, whats

happening is that yung tao, nauna na yung entry kesa

yung application. So kung ano yung possession mo, yun

yung ina-applyan mo but that is not how it is supposed

to be. Supposedly, papasok ka lang sa area when your

application is approved.

So if you are allowed entry, what is the nature of your

possession?

Syempre, when you enter the land, necessarily you

possess the land. So what is the nature of your

possession as a homestead applicant? Remember, the

patent has not yet been issued. Your still in the process

of complying with the requirements of cultivation.

Before the approval of the homestead

application, sinabi ko kanina, yung applicant has no

right at all to enter the land. No rights to possess the

land. But after the application is approved, just to

reiterate, entry is authorized. If you are authorized toenter, you have the right to cultivate and the right to

acquire title to the land after compliance with the

requirements on cultivation. Then, the right to be

notified in case of a cancellation of the homestead

entry. This is the case of Ayson vs. Republic(November

29, 1954.)

Now, what are the conditions on the authority

to possess prior to the completion of the requirements?

Nakapasok ka na, you are cultivating already but di mo

pa nacocomplete ang period of requirements ofcompletion. Your right is not indivisible. Your right of

possession is not indivisible. It doesnt mean that when

you are allowed entry that the land is subject of your

application can no longer be awarded to other tenants.

More significantly, your possession of the land

does not deprive the Director of Land of his control over

the disposition of that land and the adjudication of the

same in favour of other applicants or tenants. More

often, there is an overlapping of claims between

applicants. One cannot claim superior right over the

other because the possession cannot be indivisible. A

what Ive said, it doesnt mean that the Director o

Lands would lose jurisdiction over the land.

After the completion of the land requirement

(cultivation) and even before the issuance of the patentthe right of the homestead applicant becomes a vested

right. Meaning, the homesteader here becomes an

equitable owner. More significantly again, the land

becomes a private land. Remember these three.

When is homestead ownership determined therefore?

The date of acquisition of the ownership is determined

from the time when the applicant fully complied with

the requirements of the Public Land Law for the

acquisition of the patent, not from the issuance of the

patent but from the time he is able to comply with the

requirements on cultivation.

CA 141 covers only alienable lands of the public

domain. So, lands which have been previously

adjudicated to a patentee and a certificate of title has

already been issued, the same can no longer be furthe

adjudicated by the Director of Lands because once the

land becomes a private land, the same is taken away

from the jurisdiction of the Director of Lands. It is

already a private land.

Lets talk about transfer of rights, sale or mortgage of ahomestead before the expiration of prohibitory period.

May an applicant of a homestead patent be allowed to

transfer his rights after the approval of his application

but before issuance of a title?

Section 20 of CA 141. The answer to this is generally no

The general rule is no. He cannot transfer his rights

after the application is approved or before the issuance

of the patent.

Exceptions: First, the applicant has already

complied with all the requirements of the law that hecannot continue of his application on his own. The

transfer is made to a purchaser who is legally qualified

to acquire a homestead. And the transfer is not made

for purposes of --- or to sell it for a higher price. Lastly

there must be an approval of the Director of Lands.

Let us talk about the prohibitory period. It is counted

from the issuance of the patent.


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What is the effect of a sale of homestead during the

prohibitory period? It is null and void.

What is the effect of mortgage, alienation or

encumbrance during the said period? Again, it is null

and void.

Even if the sale is approved by the Director of Lands, the

sale is still void. Even if the mortgage is made with theconsent of the DoL, it is still void. Even if the sale is

ratified after the prohibitory period, the sale or

mortgage is void. Kaya sinasabi ko, the prohibition is

absolute within the prohibitory period.

What is the rationale behind this?

The Supreme Court, in the cases of Ortega vs.

Tan (January 23, 1990) and Delos Santos vs.

Roman Catholic Church (Feburary 25, 1954),

said The prohibition of the law which prohibits

the sale or encumbrance of the homestead

within the prohibitory period is mandatory. This

cannot be defeated even with approvals

granted beyond the expiration of the period

because the purpose of the is to promote a ---

policy which is to preserve and keep in the

family of a homesteader that portion of the

public alnd which the State has gratuitously

given to him

In other words, it would render the very spirit

of the law as naught and meaningless. It is going to

render CA 141 as balewala. After the prohibitory period,the 5 year, meron din siyang 25-year prohibitory period

but the period of 25 year prohibition is not mandatory

but only directory. Di kailganan sundin except when

constitutional issues are present.

Read these cases: Flores vs. Placima(50 OG 73), --- vs.

Montano(Gr. No. L-5567)

Within the 25-year prohibitory period, the

approval of the DoL is necessary. If you sell a

homestead within the 25-year prohibitory period, hindimo kailangan agad-agad makuha ang consent ng DENR

Secretary or Director of Land, but you can get it

anytime. Kapag kumuha ka ng consent, the same cannot

be denied. Well, except, sabi ko nga, on constitutional

grounds.

Section 119 of CA 141 provides a right of redemption.

Every particular piece of of land acquired under

homestead or free patent, provision of RA --- shall be

subject to repurchase by the applicant, his widow o

legal heirs within a period of 5 years from the date o

conveyance.

So, if you sell it now, you still have 5 years in

which to redeem the homestead. You can read

the case of Belisario vs. IAC (165 S 101). So

take note that the right of repurchase under CA141 is a right. It is not an obligation. It is

transmissible and it cannot be waived even if

the waiver is part of the Deed of Sale.

If you sell a homestead and one of the

provisions therein is a waiver on the part of the seller to

re-acquire or repurchase the property, the same is void

Your right of repurchase under CA 141 automatically

becomes of the sale even if this provision does not

appear in the Deed of Sale. It is impliedly written in the

Deed of Sale. What would govern is the law on Section

119 of CA 141.

When are you going to count the 5 year period of

repurchase?

Depende yan if it is voluntary. If voluntary, from the

date of sale. If involuntary, for example foreclosure o

the property and subjected to public auction sale, the

period is counted from the expiration of the 1 year lega

redemption period. And the legal redemption period

usually, is counted from the date of registration in the

Registry of Deeds, not on the date of sale.

How do you construe the term heirs?

The Supreme Court said, in the case o

Madapos vs. Dela Merced (174 S 599), the term

legal heirs is used in Section 119 in its generic

sense. It is broad enough to cover any persons

called to the succession either by provision in a

will or by operation of law. Thus, legal heirs

include all testate and intestate heirs depending

upon whether the succession is by the will of

the testator or the law.

The enumeration under Section 119 of CA 141 is

not an exclusionary rule. It merely enumerates

the persons qualified under the law to make the

repurchase. So, nakalagay kasi sa Section 119

subject to repurchase of the applicant, by his

widow or his legal heirs. Walang preference sab

ng SC. But when the seller is still living, he is the

one who has the right of redemption. This is the

case of Umengan vs. Butacan(7 SCRA 311).


10/16


What is the purpose of right of repurchase? Bakit

merong right of repurchase?

This is answered in the case of Ferrer vs.

Magante (50 SCAR 424) in reference toRivera

vs. Oramen (24 SCRA 448) where the Supreme

Court said The applicant for a homestead is to

be given all the inducement that the law offersand is entitled to its full protection. The policy

of the law is not difficult to understand.

The incentive for a pioneer to venture

into developing virgin land becomes more

attractive if he is assured that his effort will not

go for naught should perchance his life be cut

short. This is merely a recognition of how

closely bound parents and children are in a

Filipino family. Logic, the sense of fitness and of

right, as well as pragmatic considerations thus

call for continued adherence to the policy that

not the individual applicant alone but those so

closely related to him as are entitled to legal

succession may take full advantage of the

benefits the law confers.

As I said before, if it involves a voluntary sale,

the 5-year period of repurchase is counted from the

date or conveyance. If it is an involuntary sale, it is

counted from the expiration of the 1 year legal

redemption period.

The Supreme Court, in the case of Belisario vs.

IAC (165 S 101) and East Bank vs. CA (174 S

619), said The target period of redemption in

Section 119 of CA 141 begins run after the

expiration of the one year period of the

purchase of the land in an extra-judicial

foreclosure. The period is reckoned from the

date of registration of the certificate of sale on

the Registry of Properties concerned and not

from the date of option sale. So thats very

clear.

Right of repurchase when properly exercised.

Lee vs. CA (November 28, 1975)The Supreme

Court said that the right of repurchase is

deemed to have been exercised only when

tender of oayment has been made by the

vendor. It not sufficient for the vendor to

intimate or to state to the vendee that the

former desires to redeem the thing sold, but he

must immediately thereupon offer to repay the

price.

So within the 5-year period of repurchase

before the expiration of the period, the homesteade

shall offer to pay. Hindi enough yung sasabihin lang niya

na I'm going to repurchase. It must be more than thatIn this case, the SC said you must immediately offer to

pay. Dapat sabihin na I'm going to redeem and I'm going

to say. There must also be a tender of payment. I

tender mo ang bayad mo.

What do we understand by tender of payment?

In the case of Roman Catholic Bishop of

Malolos vs. IAC (November 16, 1990), the

Supreme Court said "Tender of payment

involves a positive and unconditional act by the

obligor of offering legal tender currency as

payment to the obligee for the formers

obligation and demanding that the latter accept

the same." Offer legal tender, ibig sabihin cold

cash.

However, in the case of Francisco vs. Bautista

(December 19, 1990), the Supreme Court said

that when you make a tender of payment... it

must be followed by consignation in court

Once a consignation is made, the obligation is

made. The Supreme Court also said that "In

instances where no debt due and owingconsignation is not proper. Consignation is not

required to preserve the right of repurchase a

a mere tender of payment is enough if made on

time as a basis for an action to compel the

vendee a retro to resell the property."

Further, the Supreme Court said where valid

tender of payment is made pursuant to the ---, the right

of repurchase is a right. It is not an obligation. So, within

the five year repurchase period, it is enough to preserve

the right in a valid tender of payment. If hindi gi-acceptng creditor, even beyond the 5 year period, the right o

repurchase is still there.

Tan vs. CA(172 S 660): "Legal redemption is in

the nature of a privilege created by law partly

for reasons of public policy and partly for the

benefit and convenience of the redemptioner

to afford him a way out of what might be a


11/16


disagreeable or inconvenient association into

which he has been thrust."

That is the rationale behind the right given to the

homesteader to repurchase the property. It is a

privilege created by law for reasons of public policy and

partly for the benefit and convenience of redemptioner.

For rural banks, there is a different period of

repurchase. You read the case of Rural Bank of Davao

vs. CA (217 S 554). Pag-rural bank ang nag-foreclose, the

legal redemption period is 2 years. So, if you add 5 years

to the 2 years, the period of redemption in favor of the

homesteader is now 7 years.

What would be the redemption price?

Article 1616 on the New Civil Code in relation to Article

597 and 546, the redemption price would be the price

of sale + necessary expenses and useful expenses.

Necessary expenses are those incurred for the

preservation of the land. Useful expenses are those

which increase the value of the thing or augment the

income of the thing.

The house constructed on a homestead is a

useful homestead. The homesteader has an

option either to require the vendee a retro to

remove the useful improvement on the land

subject to the sale a retro or to pay for for the

useful improvement introduced by the vendeea retro. This is the ruling in the case of Calagan

vs. CFI of Davao (95 S 498).

Section 28 of Rule 39 of the Rules of Court: The

redemption price would be the purchase price plus the

interest plus assessments and taxes. So if you are going

to fuse Section 28 and Article 1616, you add the

necessary expenses and useful expenses in the

enumeration. Actually, in assestments, taxes are

considered necessary expenses. So, you included there

in the enumeration of useful expenses. So, purchaseprice, interests, taxes as well as useful expenses.

Cross-reference: Salinilias vs. CA (169 S 829). What are

the instances when the right to redemption is not

applicable?

1.

When the conveyance was made to an

immediate member of the family of a

homesteader and to his direct descendants and

heirs. (So, walang instance na lalabas yung

homestead sa family circle.)

2.

Where the exercise of the right of repurchase i

not for the purpose of preserving the land

within the family circle but to dispose of it once

again for a greater profit.

3.

Where the land is no longer devoted to

agricultural purposes but converted toresidential and commercial purposes. (So wala

na yung essence ng agriculture which is the very

reason why the homestead is granted to the

homesteader. Once converted to other uses

the right of redemption is lost.)

Let's now take up sale.

For your reference, read the case of Jimenez vs

Macaraig (219 S 230). Who are qualified to purchase

agricultural land? Filipino citizen of legal age and head

of family. Sale is not allowed to corporations by express

provision of the 1987 Constitution, Sec. 3 of Article 12

Maximum area allowed is only 12 hectares.

Take note of the procedures in acquiring of agricultura

lands through sale.

First is the filing of the application followed by the

appraisal then publication of the notice of sale

submission of bids, the award to the highest bidder and

of course, the payment of the selling price.

What are the conditions of the issuance of the sale'spatent?Take note of the conditions.

1.

The purchaser must cultivate not less than 1/5

of the land within the 5 years from the date of

award.

2.

The purchaser must show actual occupancy

cultivation and improvements for at least 1/5 o

the land applied.

Upon compliance with conditions 1 and

2, there will be a survey of the area. After the

survey of the area, the sales parent is issued. Iyou are issued a patent, you have to register it

under PD 1529 to be covered by the Torren's

System of Registration. Iba yung patent, iba

yung registration of title. The patent evidence

the grant by the government under CA 141 but

that is not enough to come under the

protection of the system of registration. So the

patentee still needs to register it under the

Registration Decree or PD 1529.


12/16


Assuming you are occupying the land, you are still

cultivating it and the patent is to be issued, meron ka

bang rights to sell?

CA 141 allows the sale of an applicant over a sales

patent application provided that the sale does not

affect the interest of the government of the land and

the sale is made to a transferee who is qualified. Thetransferee must not be deliquent and the sale must be

approved by the DENR.

1.

Take note also of the restrictions. What are the

restrictions? Yung limitations nasa Sections 128,

110. 111, 112, 131 and 132. The more

important restrictions are:

1.

There is a 10 year prohibitory period from the

issuance of the sales patent on encumbrance,

conveyance and disposal. So a patentee cannot

encumber ir dispose of the land within the

prohibitory period.

2.

Joint ventures are not also allowed.

3.

Take note of the special limitation under

Section 122 where it provides that lands

originally acquired under CA 141 (homestead

patent, homestead patent, sales patent) shall

not be encumbered, alienated or transferred

except to a person or corporation who may

acquire lands of the public domain under CA

141. Tandaan niyo yan. There is a big

implication.

So if you are a buyer of a land originally

disposed of under the provisions of CA 141, there might

be a danger that the sale would be declared null and

void if you are not qualified. The sale must be made in

favor if a person or corporation qualified or allowed

under CA 141 to own lands of the public domain.

There is no issue with respect to a natural

person because a Filipino citizen is qualified to acquire

lands of the public domain. So, the sale made by a

homestead patentee or a sales patentee to a Filipinocitizen, pwede yan. No danger. But when the buyer is a

Filipino corporation, you have to determine whether or

not that Filipino corporation is qualified under CA 141

to acquire lands of the public domain.

What are those corporations qualified under CA 141?

Corporations for commercial, industrial, educational,

religious or charitable purposes. These are the only

corporations which are allowed to acquire lands of the

public domain.

So any corporations which buy a land originally

disposed of under CA 141 and those not enumerated

above (under CA 141), there is a likehood that the sale

would be null and void. Take note of this.

Sa lease naman. Cross-reference Section 23 of CA 141

and Section 3 of Article 13 of the Constitution.

This time, Filipino corporations owned by at

least 60% owned Filipinos are qualified to lease lands of

the public domain. What is the maximum area allowed

for Filipino citizens, we have not more than 500

hectares and for Filipino corporations not more than

1000 hectares. Foreign corporations are not allowed to

lease agricultural lands of the public domain.

What is the period of lease? 25 years.


Cross-reference Section 24-27 of CA 141. Similar to sale

ang process. There must be an application, then

appraisal, notice, publication, bidding and afterwards

award.

I like to stress also the restrictions on lease. Provided

under Section 14.

1.

Sub-lease is not allowed except when approved

by the DENR Secretary. 2. Sub-lease is not alsoallowed to those not corporations and citizens

not allowed to acquire public lands.

2.

The lessee is restricted to remove or dispose o

timber except as permitted by exisiting fores

regulation (PD 705.)

We're done with sales and lease. Next meeting, we are

going to discuss confirmation of imperfect title.

---- END OF SECOND EXAM ----


13/16


Okay, confirmation of imperfect or incomplete title.

There are two ways to confirm or to perfect an

incomplete title.

1.

Judicial legalization

2.

Administrative legalization or Free Patent under

the provisions of CA 141

Lets go directly to procedure of application forjudicial legalization. As the term suggests, the

application is filed for by the courts. Section 43 of CA

141 provides that it must be made in accordance with

the Land Registration Act. The Land Registration Act is

now PD 1529 or Property Registration Decree.


1.

The applicant shall cause the survey of the land

applied for.

Kasi pag-sinabi mong confirmation of

imperfect title, when would this happen? If you

are in possession of a public land which is

alienable and disposable for at least for 30

years, then what you need to do is to have it

confirmed. Under the law, the lapse of at least

30 years would make the applicant or the

possessor the equitable owner of the land.

Wala lang siya titulo and to have titulo, he

needs to apply for the confirmation of the title.

So, this is an example of the exception

that prescription does not lie against the

government. The general rule is that

prescription does not lie against thegovernment and the exception is when the

government gives its consent. CA 141 is an an

example of the consent given by government

for prescription.

2.

The survey will be attached to the application to

be filed via petition to the courts.

3.

There will be an initial hearing.

4.

The court orders service of notice to interested

parties.

It is addressed to the general public

that Mr. Juan de la Cruz is claiming ownership ina public land attached therewith is a survey.

Those of you who have interest over the

property shall file comment or opposition for

the application of the imperfect title.

5.

If there is an opposition, the procedure will be

more tedious.

For reason of due process, the court is

mandated to hear the opposition or petition.

6.

There would be a hearing and decision of the

court. After promulgation, there would be

issuance of the decree of the court and

registration must be made in accordance with

the Land Registration Act (or Land Registration

Authority).

7.

There will be registration in the Registry of

Deeds.

After following the procedures, that is the time

that a persons possession or property rights will come

within the protection of the Torrens System of

Registration.

What is the difference between Land Registration Ac

(PD 1529) and the Public Land Act (CA 141)?

If you find for a confirmation of imperfect title

before the courts, under CA 141, you have to follow the

procedures outlined under PD 1529, that is you file a

petition before the court. If you file a homestead unde

CA 141, you follow the procedures under CA 141. If one

applies under the provisions of PD 1529, and the other

one applies also for the similar application of the

Homestead law, ano ang difference ng procedure nato?

Judicial legalization under PD 1529 and Homestead

provisions under CA 141?

1.

Under the LRA, the right of title of the applican

is presumed to exist. If you are the applicant

udner the provisions of the Property

Registration Act, ang sinasabi mo is that this

land is mine. Akin ito, because I possess this foat least 30 years. I am now considered as the

equitable owner by virtue of prescription. It is

presumed that when you apply, you are

presumed to be the rightful possessor and

owner of the land. Ang hinhigi mo lang is the

confirmation. BUT under CA 141, no such

presumption over the right of the title. If you

file a homestead petition, ang sabihin nun is

that the property is owned by the government

What you are saying is, bigyan niyo ako ng lupa.

2.

Under the LRA, right of the title of the land issought to be confirmed while under the PLA

the land is under claim of ownership.

3.

Under LRA, dismissal of the court may be

subject to re-application. Under PLA, dismissa

bars future petition.

4.

Under LRA, notice of losing the land (?). Unde

PLA, once application is denied, the person

loses the land without affording anothe

chance.


14/16


As Ive said earlier, Section 41 of CA 141, this

one of the examples where the State gives consent for

prescription. In relation to Article 1113 of the NCC

Under Section 48 of CA 141, the burden of proof lies

with the state to prove that the land is really a public

land. So magkaiba na ngayon yung position. So, if you

are claiming or applying under the provisions of LA,particularly PD 1529, the burden of proof lies on the

part of the state to dispute the presumption. Again, the

presumption is that the land is owned by the applicant.

It is the obligation of the state to show otherwise, or

that the land is inalienable or disposable, or that

prescription has not set in.

Take note that juridical persons are disqualified

to apply for judicial confirmation of imperfect or

incomplete title under the provisions of CA 141. But you

read these cases

1.

Director of Lands vs. Lo-od (134 S 463)

2.

Director of Lands vs. IAC (146 S 509)

3.

De Ocsio vs. CA (February 28, 1989)

Lets go to administrative legislation. The term

suggests administrative, its non-judicial. You file it with

the Bureau of Lands. Administrative legalization of

imperfect title, so yung venue yung magkaiba.

The procedures under the Bureau of Lands are

simple. Its more simple.

1.

Apply with the BoL, then the BoL will justmake sort of notice (posting of notices sa

iba-ibang lugar).

2.

There would be investigation before survey.

3.

If survey is approved, the plan is drawn.

4.

Then issuance of the patent.

Although the procedure is more simple, it

would take several years before the title or patent is

issued. Mas mabilis pa rin sa court kesa Bureau of

Lands. Now, after the patent is issued, the land

becomes private. Francisco vs. Villegas (145 S 87)

Although some cases would suggest that when

a parcel of land is occupied by an individual, then

prescription had already set in, the land is already

segregated from the mass of the public domain. In

other words, the land no longer becomes part of the

public domain.

Sabi ng court, in order for the right to ripen to a

patentable title, kailangan mo pa rin mag-apply para

magkaroon ka ng titulo. So that would be a concrete

evidence that the land is already segregated from the

land of the public domain. Its a proof of ownership ove

the parcel of land. Case of Naval vs. Jonsay (50 OG

4792)

In your study of land titles and deeds, the free

patent is deemed final and conclusive. One year from

the date of promulgation of the patent. One year before

the title becomes indefeasible. So, the indefeasibility o

the title is conclusive one year after the issuance of the

patent. The exception is when the title is confirmed

through fault.

Director of Lands vs. Abanilla (124 S 358): The

Supreme Court was categorical when it said that the

certificate of title cannot be used as a shield to ---.

Take note of the restrictions under Section 118

of CA 141, sa free patents. Merong mandatory

prohibitory of 5 years from the issuance of the patent. I

cannot be sold, encumbered or alienated within the

said prohibitory period.

So, lets go to Minerals.

Refer to Section 2 of Article 12 of the 1987 Constitution

1.

The exploration, development, and utilization o

natural resources shall be under the full controand supervision of the State. The State may

directly undertake such activities, or it may

enter into co-production, joint venture, o

production-sharing agreements with Filipino

citizens, or corporations or associations at least

60 per centum of whose capital is owned by

such citizens.

2.

The President may enter into agreements with

foreign-owned corporations involving eithe

technical or financial assistance for large-scale

exploration, development, and utilization ominerals, petroleum, and other mineral oils.

What are the limitations?

1.

Financial and technical assistance.

2.

Large-scale exploration, development and

utilization of minerals.

Ano yung pwede ienter ng President into

agreements? With foreign owned-corporations pero


15/16


limited lang. Refer above. Tsaka, it involves only mineral

lands, hindi pwede ang forest lands.

In the case of La-Bugal Blaan, the decision of

the Supreme Court on the issue on WON the provisions

under the Mining Act of 1982 allowing foreign-owned

corporations to directly mine the mineral lands, pwede

ba? The constitution says that their participation is onlyfor financial and technical assistance. In other words,

they cannot engage in actual mining operations.

But the Philippine Mining Act of 1982 provides

for a situation where foreign-owned corporations may

directly undertake actual mining operations. That

provision was assailed as unconstitutional. The

constitution does not allow it. The Supreme Court

decided that the provisions RA 7942 is unconstitutional.

But then, the respondents filed a motion for

reconsideration. The SC then said that it is

constitutional. The SC justified it by the maount of

money or profit the government will generate from the

operations of the foreign-owned corporations. So that

paved a way for the entry of foreign-owned

corporations.

Under the Spanish Regime, ang sinusunod is the

concept of jura regalia. All natural resources belong to

the crown, or to the king. If you want to exploit, you get

a decree from the king. During the American regime, we

have the Philippine Bill of 1902 where the disposition of

mineral resources of the public domain was reserved tothe state, nawala na yung ownership by the crown but

ownership by the state. So, the exploration and

exploitation are open to both Filipinos and Americans.

During the American regime, Americans were allowed.

Take note of other related laws, RA 1776 as well

as RA 7952. Maraming important laws like Petroleum

Act, Coal Development Act, Mineral Resources

Development Decree. Ito yung mga lumang batas but

they are still good. Although yung mga ibang laws on

mining, nawala na ito. Nadagdagan ng bago. At present,we are using the Philippine Mining Act of 1995, not

1992.

Take note of the definition of minerals and

mineral lands. Also the classification of mineral lands.

If we go by the old definition, we have four

kinds of mineral lands. We have the metal, precious

stones, fuels (lands containing combustible materials)

salines, mineral waters, granite.

The small-mining act would only refer to meta

or metal--- ores. Yung particularly gold and tsaka silver

RA 7076 does not cover precious stones, jewels and

salines and mineral waters.

What office is charged with the administration

of mining laws? DENR. The findings of facts of the DENR

is conclusive and cannot be changed unless there is a

grave abuse of discretion.

What is the maximum area allowed? With

respect to individuals, we have 500 has, and 1000 has

entire Philippines. For mining partnership, 5000 has in

province and 10000 has entire Philippines. For mining

corporations, 10,000 has.

Take note of the areas close to mining locations

You read the case of Baguio Gold Mining vs. CA (July 18

1991) and the case of Apex Mining vs. Garcia (July 16,

1991).

There are two cases here which Id like to

discuss in relation to mineral lands.

The case of Ungay M Mines, Inc. vs. IAC

(September 1987): An individual filed an application fo

the said agricultural purposes. Ito yung lupa, nag-apply

siya. Pero dito, this man also applied for miningoperations. The issue here is WON a land can be

classified as both agricultural and mineral. Can they co

exist? Under the premise that the said land can be

classified as both mineral and agricultural, the SC said

the issuance of load patents on mineral palce by the

President of the Philippines in 1962 in favour of the

petitioner, granted to it only the right to extract or use

the minerals which may be found on or under the

surface of the land. On the other hand, the issuance of

the free patents by the Director of Lands in 1979 in

favour of respondents, granted to them the ownershipand rights to use the land for agricultural purposes bu

excluding the rights to use or extract the minerals which

may be found on or under the surface.

What the SC is saying is that both can co-exist

The land may be classified as both agricultural and

mineral. Depende na, may limitation. If you are granted

free patent, sayo lang ang sa taas. You use it fo

agricultural purposes but you have no right over the


16/16


minerals found therein. Kung ikaw naman ang nabigyan

ng right to mine, sa baba ka lang. You cannot prevent

others from utilizing the land.

But then, one year later, thatshow --- the SC is.

In the case of Atok vs. CA, decided April 15, 1950. The

SC said the rights over the land are indivisible. The land

cannot be half agricultural and half mineral. Theclassification must be categorical, in that the land must

be completely mineral or completely agricultural. It can

never be both. The land which was originally classified

to be agricultural ceased to be so mineral and

completely mineral once ---. Kapag mineral yan, mineral

na yan. Memorize the case of Atok (digest).

What is the rule? The rule is that once minerals

are discovered in the land, whatever the use to which it

is devoted at that time, such use may be discontinued

by the state to enable it to extract the minerals therein

in the exercise of its sovereign prerogative. It may be

converted to a mineral land and may not be used by any

party, including its registered owner. In other words,

even if you are now the owner of a private land like 2

has of agricultural land and naay nakita na mina, the

natural resources even found in the private land, belong

to the state. So the state may take back your land to

mine the resources. Of course, there is payment of just

compensation.

---- END OF THIRD EXAM ----

natres transcription - atty. batacan (la)

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