**Facts:**
1. **Initial Purchase and Possession (1952-1954):**
– Pablo Feliciano bought a parcel of land comprising four lots (total area: 1,364.4177 hectares) from Victor Gardiola through a Contract of Sale in 1952 which was confirmed by a Deed of Absolute Sale in 1954.
– Feliciano claimed to have taken possession of the land, introduced improvements, and had it surveyed, which was approved by the Director of Lands.
2. **Issuance of Proclamation No. 90 (1954):**
– President Ramon Magsaysay issued Proclamation No. 90, reserving land in the Municipalities of Tinambac and Siruma, Camarines Sur, for settlement purposes under the National Resettlement and Rehabilitation Administration (NARRA).
3. **Land Dispute and Initial Court Proceedings (1970-1971):**
– Feliciano filed a complaint for recovery of ownership and possession of the land on January 22, 1970.
– The Court of First Instance (CFI) ruled in favor of Feliciano in August 1970, recognizing Lot No. 1 (701.9064 hectares) as Feliciano’s property but reverted Lots 2, 3, and 4 to public domain.
– Eighty-six settlers intervened, alleging long-term possession that predated the purchase by Feliciano. This led to a reconsideration and reopening of the case in January 1971.
– The intervenors failed to appear for their hearing, resulting in Feliciano again being favored by a decision in August 1971.
4. **Procedural Complications and Appeals (1971-1985):**
– The lower court reopened the case again in December 1971 to allow the intervenors another chance to present their evidence.
– Feliciano’s subsequent petition for certiorari to the Intermediate Appellate Court and the Supreme Court was unsuccessful.
– Eventually, on August 21, 1980, the CFI dismissed the case on grounds of non-suability of the state, which Feliciano contested but the Solicitor General supported.
– The Intermediate Appellate Court reversed the dismissal in April 1985, prompting the Republic to seek this review.
**Issues:**
1. **Non-Suability of the State:**
– Whether the Republic of the Philippines can be sued for recovery of ownership and possession of a parcel of land without its consent.
2. **Validity of Possessory Information:**
– The legitimacy and sufficiency of the “informacion posesoria” relied upon by Feliciano to claim ownership of the disputed land.
3. **Immunity Waiver Contention:**
– Whether Proclamation No. 90 impliedly waived the state’s immunity from suit by stating “subject to private rights, if any there be.”
**Court’s Decision:**
1. **Non-Suability of the State:**
– The Supreme Court held that the doctrine of non-suability of the state applies. The action is characterized as an in personam action, directly seeking to litigate against the Republic and bind it by the judgment.
– The complaint against the Republic did not demonstrate any statutory consent to be sued, thereby making it dismissible on this ground.
2. **Validity of Possessory Information:**
– The Court acknowledged that the “informacion posesoria” remained prima facie evidence of possession and was never converted into a record of ownership. Moreover, the authenticity of the possessory information was highly questionable as it was a reconstituted document without sufficient proof of its original validity.
– The properties exceeding the area stated in the possessory documentation further rendered its legitimacy dubious.
3. **Immunity Waiver Contention:**
– The Court rejected the argument that Proclamation No. 90 implied a waiver of state immunity. The exclusion of private rights from the reservation did not establish an expressed or implied consent for the state to be sued, nor could such a waiver be derived from a non-legislative act.
**Doctrine:**
– **Non-Suability of the State:**
– Consent to be sued must be expressly given by statutory authority and cannot be inferred from non-legislative actions or statements. Waiver of immunity must be strictly construed.
**Class Notes:**
– **Non-Suability of the State:**
– A suit against the state is not permissible unless an explicit waiver of immunity is provided by law.
– Even a case construed as depriving the state of property inherently amounts to an impermissible suit against the state unless there’s consent.
– **Possessory Information:**
– Under Spanish law, possessory information could lead to a record of ownership after a statutory period and fulfilling certain requirements. Failure to convert possessory information into a record of ownership limits its legal standing in later disputes.
**Historical Background:**
– **Land Registration in the Philippines:**
– The Spanish Mortgage Law and American land registration systems differed significantly. The former provided mechanisms like “informacion posesoria,” which required conversion into permanent titles post certain conditions. The transition to a more formalized Torrens system aimed to streamline land registration and ownership verification. This case highlights the complexities arising from historical land documentation practices versus modern registration requirements.
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