Faustino Ignacio vs Director of Lands (GR L-12958; May 30, 1960)

Facts:
Ignacio applied for the registration of a parcel of a mangrove land in Rizal. It was stated in the application that he owned the parcel by right of accretion. The director of land opposed the registration for the reason that the land to be registered is an area of public domain and that the applicant nor his predecessor-in-interest possessed sufficient title for the land. The parcel of land applied was acquired from the government by the virtue of a free patent title. However, the land in question was formed by accretion and alluvial deposits caused by the action of the Manila bay. The petition was denied by the lower court and decided that the land to be registered are part of the public domain. Faustino, however, contended that the court could have declared the land not to be part of the public domain.

Issue:
Whether or not the courts have the power to reclassify a land

Ruling:
No, the courts do not have the power to reclassify a land. The courts are primarily called upon to determine whether a land is to be used for public purpose. However, it is only limited there. A  formal declaration of reclassification of land should come from the government, specifically from the executive department or the legislature. These bodies should declare that a land in question is no longer needed for public use, some public use or for the improvement of national wealth.

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