All lands of whatever classification and other natural resources not otherwise appearing to be clearly within private ownership are presumed to belong to the State.
To overcome the presumption of State ownership, the applicant must establish through incontrovertible evidence that the land sought to be registered is alienable or disposable based on a positive act of the government. (Republic v. Bantigue, GR No. 162322, March 14, 2012; See also: Agcaoili, Property Registration Decree and Related Laws, 2011 ed.)
