Republic of the Philippines v. Rev. Claudio R. Cortez, Sr.

Summary

Rev. Cortez, a missionary, claimed possessory rights over 50 hectares of Palaui Island since 1962 and sought injunction against Navy interference. The RTC and CA granted final injunction, finding valid possessory rights despite government proclamations reserving the area for military and marine protection purposes. However, the Supreme Court reversed, establishing the fundamental principle that inalienable public domain land cannot be the subject of possession under Civil Code Article 530. The Court ruled that without proof that the land was declared alienable and disposable before occupation, it remains part of the inalienable public domain, making any claimed possessory rights legally impossible regardless of the length or nature of occupation. This decision clarifies that the Regalian Doctrine prevents acquisition of rights over public domain land through mere possession.