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    Director of Lands V.S Villareal

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    Mhay Khaeyl Badajos AndohuYhan
    This case involved a dispute over 178,118 square meters of mangrove swamps in Sapian, Capiz. Ruperto Villareal applied to register the land, claiming possession for over 40 years. However, the Director of Forestry opposed this, arguing the land was classified as forestal land and not subject to private ownership. The Supreme Court ruled in favor of the Director of Forestry, finding that mangrove swamps are considered public forest land under Philippine law unless specifically reclassified. As the land had not been reclassified, it remained forest land that could not be registered under private ownership.

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    Director of Lands V.S Villareal

    Uploaded by

    Mhay Khaeyl Badajos AndohuYhan
    69 views1 page
    This case involved a dispute over 178,118 square meters of mangrove swamps in Sapian, Capiz. Ruperto Villareal applied to register the land, claiming possession for over 40 years. However, the Director of Forestry opposed this, arguing the land was classified as forestal land and not subject to private ownership. The Supreme Court ruled in favor of the Director of Forestry, finding that mangrove swamps are considered public forest land under Philippine law unless specifically reclassified. As the land had not been reclassified, it remained forest land that could not be registered under private ownership.

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    Director of Lands v.s Villareal

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    This case involved a dispute over 178,118 square meters of mangrove swamps in Sapian, Capiz. Ruperto Villareal applied to register the land, claiming possession for over 40 years. However, the Director of Forestry opposed this, arguing the land was classified as forestal land and not subject to private ownership. The Supreme Court ruled in favor of the Director of Forestry, finding that mangrove swamps are considered public forest land under Philippine law unless specifically reclassified. As the land had not been reclassified, it remained forest land that could not be registered under private ownership.

    Copyright:

    © All Rights Reserved
    Download as DOCX, PDF, TXT or read online from Scribd
    Download as docx, pdf, or txt
    69 views1 page

    Director of Lands V.S Villareal

    Uploaded by

    Mhay Khaeyl Badajos AndohuYhan
    This case involved a dispute over 178,118 square meters of mangrove swamps in Sapian, Capiz. Ruperto Villareal applied to register the land, claiming possession for over 40 years. However, the Director of Forestry opposed this, arguing the land was classified as forestal land and not subject to private ownership. The Supreme Court ruled in favor of the Director of Forestry, finding that mangrove swamps are considered public forest land under Philippine law unless specifically reclassified. As the land had not been reclassified, it remained forest land that could not be registered under private ownership.

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    © All Rights Reserved
    Download as DOCX, PDF, TXT or read online from Scribd
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    MICHAEL JOHN B.

    ANDOHUYAN

    WEEK 5

    THE DIRECTOR OF FORESTRY vs. RUPERTO VILLAREAL


    G.R No. L-32266, February 27, 1989

    FACTS:

    On January 25, 1949, Ruperto Villareal applied for registration a 178, 118 square meters
    lot. The subject lands consist mangrove swamps located in Sapian, Capiz. He alleged that he and
    his predecessors-in-interest had been in possession of the land for more than forty years. He also
    invoked the survey plan of the mangrove swamps approved by the Director of Lands, to prove
    that the land is registerable. Some people opposed the said application including the petitioner
    representing the Republic of the Philippines. However, after the trial the court approved its
    application and was affirmed by the Court of Appeals.

    The Director of Forestry then went to the Supreme Court in a petition for review
    on certiorari claiming that the land in dispute was forestal in nature and not subject to private
    appropriation. He asks that the registration be reversed. He also contended that land under
    dispute being admittedly a part of the mangrove swamps of Sapian, and for which a minor forest
    license had in fact been issued by the Bureau of Forestry from 1920 to 1950, it must be
    considered forest land. Hence, not alienable or open to disposition contrary to the contention of
    Villareal.

    ISSUE:

    Whether or not mangrove swamps, or manglares are part of agricultural or public forest
    lands and open for disposition?

    RULING:

    No, the subject land is not open for disposition and alienable. Mangrove swamps
    or manglares should be understood as comprised within the public forests of the Philippines as
    defined in Section 1820 of the Administrative Code of 1917. forest' includes, except as otherwise
    specially indicated, all unreserved public land, including nipa and mangrove swamps, and all
    forest reserves of whatever character. Swampy areas covered by mangrove trees, nipa palms,
    and other trees growing in brackish or sea water may also be classified as forest land.

    The contention of the respondent on the existence of a plan is incorrect because its mere
    existence would not have the effect of converting the mangrove swamps, as forest land, into
    agricultural land. To be so, it had first to be released as forest land and reclassified as agricultural
    land pursuant to the certification the Director of Forestry may issue under Section 1827 of the
    Revised Administrative Code.

    The tax declarations made by the private respondent were practically the only basis used
    by the appellate court in sustaining his claim of possession over the land in question. Tax
    declarations are not sufficient to prove possession and much less vest ownership in favor of the
    declarant as held in countless cases.

    Hence, it is clear that the subject land is not alienable under the Constitution and may not
    be the subject of private ownership until and unless they are first released as forest land and
    classified as alienable agricultural land. The decision of the CA is set aside and the application for
    title thereof is dismissed.

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