The Constitutionality of Declaring Unclassified Lands as Forest Lands: A Case Brief on The Federation of Coron, Busuanga, Palawan Farmer’s Association, Inc., et al. vs. The Secretary of the Department of Environment and Natural Resources (DENR) and The Department of Agrarian Reform (DAR)
**Facts:**
Petitioners Federation of Coron, Busuanga, Palawan Farmer’s Association, Inc. (FCBPFAI), Sandigan ng Mambubukid ng Bintuan Coron, Inc. (SAMBICO), and Samahan ng Magsasaka ng Sto. Nino (SAMMASA) are associations of farmers occupying lands in Palawan. They assert that they and their predecessors have been in continuous possession of their respective lands. The lands were purportedly placed under the Comprehensive Agrarian Reform Program (CARP) but were later determined to be unclassified forest lands under Section 3(a) of P.D. No. 705 and thus, inalienable and non-disposable by the government.
After a series of meetings with DAR where they were told that the lands they occupied could not be subject to CARP due to their classification under P.D. No. 705, the petitioners sought the courts to declare Section 3(a) unconstitutional, arguing, among other things, that the provision violated the principle embodied in the Philippine Bill of 1902, 1935, 1973, and 1987 Constitutions, which regarded “unclassified lands” not shown or in use as forest lands to be “public agricultural lands” and, therefore, alienable.
Respondents, represented by the Office of the Solicitor General (OSG), countered that the petitioners had no locus standi to file the petition and that Section 3(a) of P.D. No. 705 is presumed constitutional.
In the Supreme Court, the petitioners elevated the plea, invoking the unconstitutionality of Section 3(a) and deprivation of their alleged vested right of ownership over the occupied lands.
**Issues:**
1. Whether Section 3(a) of P.D. No. 705 is unconstitutional.
2. Whether petitioners possess the locus standi to file the petition.
3. Whether unclassified lands should be presumed as disposable and alienable.
**Court’s Decision:**
The Supreme Court dismissed the petition. It held that every law enjoys the presumption of constitutionality, and the party challenging the law bears the burden of proving its unconstitutionality beyond reasonable doubt. The court found that petitioners failed to overcome this presumption and that Section 3(a) of P.D. No. 705 is consistent with the Regalian Doctrine under Philippines jurisprudence and the 1987 Constitution. The court also found no merit in the argument that unclassified lands be presumed alienable and disposable, further emphasizing that the classification of lands is the prerogative of the Executive Department.
**Doctrine:**
1. The presumption of constitutionality of a statute. The burden of proof to overcome this presumption rests on the party challenging the validity of the statute.
2. The Regalian Doctrine, which provides that all lands of the public domain belong to the State, and the State is the source of any asserted rights to ownership of land. Only agricultural lands are alienable.
**Class Notes:**
– The Regalian Doctrine is central to the case and prescribes that all lands of the public domain belong to the State.
– Section 3(a) of P.D. No. 705 classifies lands not subject to classification as forest lands, aligning with the Regalian Doctrine.
– Locus standi requires a party to demonstrate a personal stake in the outcome of the controversy.
– The presumption of constitutionality mandates that the court affords deference to the legislative act unless there’s a clear violation of the Constitution.
– The burden of proving that a statute is unconstitutional lies with the challengers, and not the mere speculation of unconstitutionality.
**Historical Background:**
The historical context of the case hinges on the Regalian Doctrine, which has roots back to Spanish colonialism, signifying that all lands belonged to the Crown. This principle was carried over to the present Constitution where all lands and natural resources, with the exception of agricultural lands, remain state property and cannot be alienated unless specifically declared otherwise by the state. Section 3(a) of P.D. No. 705 is thus a statutory assertion of the State’s ownership over public lands until they are expressly classified as alienable and disposable by the State.
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