G.R. No.

L31666 Lepanto Consolidated Mining Company vs Manuel Dumyung

*The Director of Lands filed civil cases to annul the free patents granted to defendants before the Court
of First Instance in Baguio City.
* Defendants:Manuel Dumyung, Fortunate Dumyung and Dumyung Bonayan
* The Lepanto Consolidated Mining Company filed a motion for intervention which was granted. Its
complaint indicate that the lands within the free patents of the defendants are within their ordinary
timber license while another portion is embraced in their mineral claims
* Before the hearing of the civil cases, the Director of Lands filed criminal cases for falsification of
public documents against the defendants. Due to insufficiency of evidence, the Court dismissed the
three criminal cases. * Defendants then filed a motion to dismiss the civil case based on the dismissal
of the criminal cases against them, which the trial court granted on the following grounds:
* It clearly shows that upon the issuance of said Free Patents on November 26, 1960, the same were
duly registered with the office of the Register of Deeds of Baguio and Benguet, pursuant to the
provisions of Sec. 122 of Act 496, as amended, and consequently, these properties became the private
properties of the defendants, under the operation of Sec. 38 of said Act; hence, these titles enjoy the
same privileges and safeguards as Torrens titles . The records of this case further disclose that the
defendants are ignorant natives of Benguet Province and are members of the so-called Cultural
Minorities of Mountain Province, who are the same persons accused in the dismissed criminal cases,
based on the same grounds.
* Issue: Whether or not the dismissal of the case by the trial court was proper. Ruling: No, the dismissal
was not proper. Case is remanded to the trial court for further proceedings
* Timber and mineral lands are not disposable as per CA 141 (Public Land Act, Secs 2 and 6) -
* Sec. 2. The provisions of this Act shall apply to the lands of the public domain; but timber and
mineral lands shag be governed by special laws and nothing in this Act provided shall be understood or
construed to change or modify the administration and disposition of the lands commonly called 'friar
lands' and those which being privately owned, have reverted to or become the property of the
Commonwealth of the Philippines, which administration and disposition shall be governed by the laws
at present in force or which may hereafter be enacted.
Sec. 6. The President, upon the recommendation of the Secretary of Agriculture and Commerce, shall
from time to time classify the lands of the public domain into — * (a) Alienable or disposable, * (b)
Timber, and * (c) Mineral lands, * and may at any time and in a like manner transfer such lands from
one class to another, for the purposes of their administration and disposition.
The principal factual issue raised by the plaintiff, Republic of the Philippines represented by the
Director of Lands, and thentervenor, petitioner herein, is that the lands covered by the patents and
certificates of title are timber lands and mineral lands and, therefore, not alienable .
* The trial court, without receiving evidence, ruled in favor of the defendants
* It was premature for the trial court to rule on whether or not the titles based on the patents awarded to
the private respondents have become indefeasible. 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. The Court
enunciated in Director of Lands vs Abanzado - 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, ...'