MATEO CARIO vs THE INSULAR GOVERNMENT

Land Titles and Deeds Regalian Doctrine Statute of

Limitations
On June 23, 1903, Mateo Cario went to the Court of
Land Registration to petition his inscription as the owner of a
146 hectare land hes been possessing in the then municipality
of Baguio. Mateo only presented possessory information and
no other documentation. The State opposed the petition
averring that the land is part of the US military reservation.
The CLR ruled in favor of Mateo. The State appealed. Mateo
lost. Mateo averred that a grant should be given to him by
reason of immemorial use and occupation as in the previous
case Cansino vs Valdez & Tiglao vs Government.
ISSUE: Whether or not Mateo is the rightful owner of the land
by virtue of his possession of it for some time.
HELD: No. The statute of limitations did not run against the
government. The government is still the absolute owner of the
land (regalian doctrine). Further, Mateos possession of the
land has not been of such a character as to require the
presumption of a grant. No one has lived upon it for many
years. It was never used for anything but pasturage of animals,
except insignificant portions thereof, and since the
insurrection against Spain it has apparently not been used by
the petitioner for any purpose.
While the State has always recognized the right of the
occupant to a deed if he proves a possession for a sufficient
length of time, yet it has always insisted that he must make
that proof before the proper administrative officers, and obtain
from them his deed, and until he did the State remained the
absolute owner.

There is an existence of native title to land, or ownership of

land by Filipinos by virtue of possession under a claim of
ownership since time immemorial and independent of any
grant from the Spanish Crown, as an exception to the theory of
jura regalia.
Oh Cho vs. Director of Lands
G.R. No. 48321, August 31, 1946
GR: All lands are acquired from the Government, either by
purchase or by grant.
EXCEPTION: Lands under private ownership since time
immemorial.
Application for decree of registration is a condition precedent
to acquisition of title. Non-compliance gives rise to mere
possessory right.
An alien cannot acquire title to lands of the public domain by
prescription.
FACTS:
Oh Cho, a Chinese citizen, purchased from the Lagdameos a
parcel of land in Tayabas, which they openly, continuously
and adversely possessed since 1880. On January 17, 1940, Oh
Cho applied for registration of this land. The Solicitor General
opposed on the ground that Oh Cho lacked title to said land
and also because he was an alien.
ISSUEs:
Whether or not Oh Cho had title
Whether or not Oh Cho is entitled to a decree of registration
HELD:

Cario vs Insular Government, 41 Phil 935

(Land Titles and Deeds Native Title)
Facts: An Igorot applied for the registration of a certain land.
He and his ancestors had held the land as owners for more
than 50 years, which he inherited under Igorot customs. There
was no document of title issued for the land when he applied
for registration. The government contends that the land in
question belonged to the state. Under the Spanish Law, all
lands belonged to the Spanish Crown except those with permit
private titles. Moreover, there is no prescription against the
Crown.
Issue: WON the land in question belonged to the Spanish
Crown under the Regalian Doctrine.
Held: No. Law and justice require that the applicant should be
granted title to his land.
The United States Supreme Court, through Justice Holmes
declared:
It might perhaps, be proper and sufficient to say that when, as
far as testimony or memory goes, the land has been held by
individuals under a claim of private ownership, it will be
presumed to have been held in the same way from before the
Spanish conquest, and never to have been public land.

Oh Cho failed to show that he has title to the lot, which may
be confirmed under the Land Registration Act.
All lands that were not acquired from the Government, either
by purchase or by grant, belong to the public domain. An
exception to the rule would be any land that should have been
in the possession of an occupant and of his predecessors in
interest since time immemorial, for such possession would
justify the presumption that the land had never been part of the
public domain or that it had been a private property even
before the Spanish conquest.
The applicant does not come under the exception, for the
earliest possession of the lot by his first predecessor in interest
began in 1880.
Under the Public Land Act, Oh Cho is not entitled to a decree
of registration of the lot, because he is an alien disqualified
from acquiring lands of the public domain.
Oh Cho's predecessors in interest would have been entitled toa
decree of registration had they applied for the same. The
application for the registration of the land was a condition
precedent, which was not complied with by the Lagmeos.
Hence, the most they had was mere possessory right, not title.
This possessory right was what was transferred to Oh Cho, but
since the latter is an alien, the possessory right could never
ripen to ownership by prescription. As an alien, Oh Cho is

disqualified from acquiring title over public land by

prescription.

prescription Balbalio claimed to have received Lots 1-5 from

her father shortly after the Liberation.

Lee Hong Hok vs David

Benguet opposed on the ground that the June Bug mineral

claim covering Lots 1-5 was sold to it on September 22, 1934,
by the successors-in-interest of James Kelly, who located the
claim in September 1909 and recorded it on October 14, 1909.
From the date of its purchase, Benguet had been in actual,
continuous and exclusive possession of the land in concept of
owner, as evidenced by its construction of adits, its affidavits
of annual assessment, its geological mappings, geological
samplings and trench side cuts, and its payment of taxes on the
land.

G.R. No. L-30389, Dec. 27, 1972

FACTS:This is regarding a piece of land which Aniano David
acquired lawful title thereto, pursuant to hismiscellaneous
sales application. After approval of his application, the
Director of Lands issued an orderof award and issuance of
sales patent, covering said lot by virtue of which the
Undersecretary of Agriculture and Natural Resources issued a
Miscellaneous Sales Patent. The Register of Deeds thenissued
an original certificate of title to David. During all this time,
Lee Hong Kok did not oppose nor fileany adverse claim.
ISSUE: Whether or not Lee Hong Kok may question the
government grant
HELD: Only the Government, represented by the Director of
Lands or the Secretary of Agriculture andNatural Resources,
can bring an action to cancel a void certificate of title issued
pursuant to a void patent.This was not done by said officers
but by private parties like the plaintiffs, who cannot claim that
thepatent and title issued for the land involved are void since
they are not the registered owners thereof norhad they been
declared as owners in the cadastral proceedings after claiming
it as their private property.The fact that the grant was made by
the government is undisputed. Whether the grant was in
conformitywith the law or not is a question which the
government may raise, but until it is raised by the
governmentand set aside, the defendant cannot question it. The
legality of the grant is a question between the granteeand the
government. The decision of respondent Court of Appeals of
January 31, 1969 and its resolutionof March 14, 1969 are
affirmed.
Republic vs. CA
Republic of the Philippines, Benguet & Atok vs. Court of
Appeals
&
De
La
Rosa
G.R. No. L-43938, April 15, 1988
Doctrine: The owner of a piece of land has rights not only to
its surface but also to everything underneath and the airspace
above it up to a reasonable height. The rights over the land are
indivisible and the land itself cannot be half agricultural and
half mineral. The classification must be categorical; the land
must be either completely mineral or completely agricultural.
Facts: These cases arose from the application for registration
of a parcel of land filed on February 11, 1965, by Jose de la
Rosa on his own behalf and on behalf of his three children,
Victoria, Benjamin and Eduardo. The land, situated in Tuding,
Itogon, Benguet Province, was divided into 9 lots and covered
by plan Psu-225009. According to the application, Lots 1-5
were sold to Jose de la Rosa and Lots 6-9 to his children by
Mamaya Balbalio and Jaime Alberto, respectively, in 1964.
The application was separately opposed by Benguet
Consolidated, Inc. as to Lots 1-5, Atok Big Wedge
Corporation, as to Portions of Lots 1-5 and all of Lots 6-9, and
by the Republic of the Philippines, through the Bureau of
Forestry Development, as to lots 1-9.
In support of the application, both Balbalio and Alberto
testified that they had acquired the subject land by virtue of

For its part, Atok alleged that a portion of Lots 1-5 and all of
Lots 6-9 were covered by the Emma and Fredia mineral
claims located by Harrison and Reynolds on December 25,
1930, and recorded on January 2, 1931, in the office of the
mining recorder of Baguio. These claims were purchased from
these locators on November 2, 1931, by Atok, which has since
then been in open, continuous and exclusive possession of the
said lots as evidenced by its annual assessment work on the
claims, such as the boring of tunnels, and its payment of
annual taxes thereon.
The Bureau of Forestry Development also interposed its
objection, arguing that the land sought to be registered was
covered by the Central Cordillera Forest Reserve under
Proclamation No. 217 dated February 16, 1929. Moreover, by
reason of its nature, it was not subject to alienation under the
Constitutions of 1935 and 1973.
The trial court denied the application, holding that the
applicants had failed to prove their claim of possession and
ownership of the land sought to be registered.
The applicants appealed to the respondent court, which
reversed the trial court and recognized the claims of the
applicant, but subject to the rights of Benguet and Atok
respecting their mining claims. In other words, the Court of
Appeals affirmed the surface rights of the de la Rosas over the
land while at the same time reserving the sub-surface rights of
Benguet and Atok by virtue of their mining claims. Both
Benguet and Atok have appealed to this Court, invoking their
superior right of ownership.
Issue: Whether respondent courts decision, i.e. the surface
rights of the de la Rosas over the land while at the same time
reserving the sub-surface rights of Benguet and Atok by virtue
of their mining claim, is correct.
Held: No. Our holding is that Benguet and Atok have
exclusive rights to the property in question by virtue of their
respective mining claims which they validly acquired before
the Constitution of 1935 prohibited the alienation of all lands
of the public domain except agricultural lands, subject to
vested rights existing at the time of its adoption. The land was
not and could not have been transferred to the private
respondents by virtue of acquisitive prescription, nor could its
use be shared simultaneously by them and the mining
companies for agricultural and mineral purposes. It is true that
the subject property was considered forest land and included
in the Central Cordillera Forest Reserve, but this did not
impair the rights already vested in Benguet and Atok at that
time. Such rights were not affected either by the stricture in
the Commonwealth Constitution against the alienation of all
lands of the public domain except those agricultural in nature

for this was made subject to existing rights. The perfection of

the mining claim converted the property to mineral land and
under the laws then in force removed it from the public
domain. By such act, the locators acquired exclusive rights
over the land, against even the government, without need of
any further act such as the purchase of the land or the
obtention of a patent over it. As the land had become the
private property of the locators, they had the right to transfer
the same, as they did, to Benguet and Atok. The Court of
Appeals justified this by saying there is no conflict of
interest between the owners of the surface rights and the
owners of the sub-surface rights. This is rather doctrine, for it
is a well-known principle that the owner of piece of land has
rights not only to its surface but also to everything underneath
and the airspace above it up to a reasonable height. Under the
aforesaid ruling, the land is classified as mineral underneath
and agricultural on the surface, subject to separate claims of
title. This is also difficult to understand, especially in its
practical application.
The Court feels that the rights over the land are indivisible and
that the land itself cannot be half agricultural and half mineral.
The classification must be categorical; the land must be either
completely mineral or completely agricultural. In the instant
case, as already observed, the land which was originally
classified as forest land ceased to be so and became mineral
and completely mineral once the mining claims were
perfected. As long as mining operations were being
undertaken thereon, or underneath, it did not cease to be so
and become agricultural, even if only partly so, because it was
enclosed with a fence and was cultivated by those who were
unlawfully occupying the surface.
This is an application of the Regalian doctrine which, as its
name implies, is intended for the benefit of the State, not of
private persons. The rule simply reserves to the State all
minerals that may be found in public and even private land
devoted to agricultural, industrial, commercial, residential or
(for) any purpose other than mining. Thus, if a person is the
owner of agricultural land in which minerals are discovered,
his ownership of such land does not give him the right to
extract or utilize the said minerals without the permission of
the State to which such minerals belong.

Doctrine: In the hands of the government agency tasked and

authorized to dispose of alienable or disposable lands of the
public domain, these lands are still public, not private lands.
Facts: On November 20, 1973, the government, through the
Commissioner of Public Highways, signed a contract with the
Construction and Development Corporation of the Philippines
(CDCP) to reclaim certain foreshore and offshore areas of
Manila Bay. The contract also included the construction of
Phases I and II of the Manila-Cavite Coastal Road. CDCP
obligated itself to carry out all the works in consideration of
fifty percent of the total reclaimed land.
On February 4, 1977, then President Ferdinand E. Marcos
issued Presidential Decree No. 1084 creating PEA. PD No.
1084 tasked PEA to reclaim land, including foreshore and
submerged areas, and to develop, improve, acquire, x x x
lease and sell any and all kinds of lands. On the same date,
then President Marcos issued Presidential Decree No. 1085
transferring to PEA the lands reclaimed in the foreshore and
offshore of the Manila Bay under the Manila-Cavite Coastal
Road and Reclamation Project (MCCRRP).
On January 19, 1988, then President Corazon C. Aquino
issued Special Patent No. 3517, granting and transferring to
PEA the parcels of land so reclaimed under the ManilaCavite Coastal Road and Reclamation Project. On April 9,
1988, the Register of Deeds issued TCT Nos. 7309, 7311, and
7312, in the name of PEA, covering the three reclaimed
islands known as the Freedom Islands located at the
southern portion of the Manila-Cavite Coastal Road,
Paraaque City. On April 25, 1995, PEA entered into a Joint
Venture Agreement with AMARI, a private corporation, to
develop the Freedom Islands.
Petitioner assails the sale to AMARI of lands of the public
domain as a blatant violation of Section 3, Article XII of the
1987 Constitution prohibiting the sale of alienable lands of the
public domain to private corporations.
On March 30, 1999, PEA and AMARI signed the Amended
Joint Venture Agreement. On May 28, 1999, the Office of the
President under the administration of then President Joseph E.
Estrada approved the Amended JVA.

The flaw in the reasoning of the respondent court is in

supposing that the rights over the land could be used for both
mining and non-mining purposes simultaneously. The correct
interpretation is that once minerals are discovered in the land,
whatever the use to which it is being devoted at the time, such
use may be discontinued by the State to enable it to extract the
minerals therein in the exercise of its sovereign prerogative.
The land is thus converted to mineral land and may not be
used by any private party, including the registered owner
thereof, for any other purpose that will impede the mining
operations to be undertaken therein, For the loss sustained by
such owner, he is of course entitled to just compensation under
the Mining Laws or in appropriate expropriation proceedings.

Several motions for reconsideration of the Supreme Courts

July 9, 2002 decision which declared the amended JVA null
and void ab initio were filed. The conclusions of said decision
were summarized by the Court as follows:

Caveat: Anyone who claims this digest as his own without

proper authority shall be held liable under the law of Karma.

The 592.15 hectares of submerged areas of Manila Bay remain

inalienable natural resources of the public domain until
classified as alienable or disposable lands open to disposition
and declared no longer needed for public service. The
government can make such classification and declaration only
after PEA has reclaimed these submerged areas. Only then can
these lands qualify as agricultural lands of the public domain,
which are the only natural resources the government can

Chavez vs. PEA- Amari

Francisco I. Chavez vs. Public Estate Authority and Amari
Coastal
Bay
Development
Corporation
G.R. No. 133250. May 6, 2003

The 157.84 hectares of reclaimed lands comprising the

Freedom Islands, now covered by certificates of title in the
name of PEA, are alienable lands of the public domain. PEA
may lease these lands to private corporations but may not sell
or transfer ownership of these lands to private corporations.
PEA may only sell these lands to Philippine citizens, subject to
the ownership limitations in the 1987 Constitution and
existing laws.

alienate. In their present state, the 592.15 hectares of

submerged areas are inalienable and outside the commerce of
man.
Since the Amended JVA seeks to transfer to AMARI, a private
corporation, ownership of 77.34 hectares of the Freedom
Islands, such transfer is void for being contrary to Section 3,
Article XII of the 1987 Constitution which prohibits private
corporations from acquiring any kind of alienable land of the
public domain.
Since the Amended JVA also seeks to transfer to AMARI
ownership of 290.156 hectares of still submerged areas of
Manila Bay, such transfer is void for being contrary to Section
2, Article XII of the 1987 Constitution which prohibits the
alienation of natural resources other than agricultural lands of
the public domain. PEA may reclaim these submerged areas.
Thereafter, the government can classify the reclaimed lands as
alienable or disposable, and further declare them no longer
needed for public service. Still, the transfer of such reclaimed
alienable lands of the public domain to AMARI will be void in
view of Section 3, Article XII of the 1987 Constitution which
prohibits private corporations from acquiring any kind of
alienable land of the public domain.
Issue: Whether or not the July 9, 2002 ruling of the Supreme
Court should be reversed.
Held: No. Amari cannot claim good faith because even before
Amari signed the Amended JVA on March 30, 1999, petitioner
had already filed the instant case on April 27, 1998
questioning precisely the qualification of Amari to acquire the
Freedom Islands. Even before the filing of this petition, two
Senate Committees had already approved on September 16,
1997 Senate Committee Report No. 560 which concluded that
the Freedom Islands are inalienable lands of the public
domain. Thus, Amari signed the Amended JVA knowing and
assuming all the attendant risks, including the annulment of
the Amended JVA. Amari has also not paid to PEA the full
reimbursement cost incurred by PEA in reclaiming the
Freedom Islands. Moreover, Amari does not claim to have
even initiated the reclamation of the 592.15 hectares of
submerged areas covered in the Amended JVA, or to have
started to construct any permanent infrastructure on the
Freedom Islands. In short, Amari does not claim to have
introduced any physical improvement or development on the
reclamation project that is the subject of the Amended JVA.
PEA cannot claim that it is similarly situated as the Bases
Conversion Development Authority (BCDA) which under
R.A. No. 7227 is tasked to sell portions of the Metro Manila
military camps and other military reservations is incorrect.
PEA took the place of DENR as the government agency
charged with leasing or selling reclaimed lands of the public
domain. The reclaimed lands being leased or sold by PEA are
not private lands, in the same manner that DENR, when it
disposes of other alienable lands, does not dispose of private
lands but alienable lands of the public domain. Only when
qualified private parties acquire these lands will the lands
become private lands. In the hands of the government agency
tasked and authorized to dispose of alienable or disposable
lands of the public domain, these lands are still public, not
private lands.
To allow vast areas of reclaimed lands of the public domain to
be transferred to PEA as private lands will sanction a gross
violation of the constitutional ban on private corporations

from acquiring any kind of alienable land of the public

domain. PEA will simply turn around and transfer several
hundreds of hectares of these reclaimed and still to be
reclaimed lands to a single private corporation in only one
transaction. This scheme will effectively nullify the
constitutional ban in Section 3, Article XII of the 1987
Constitution.
Cruz vs DENR, G.R. No. 135385, December 6, 2000
Isagani Cruz v. Dept. of Energy and Natural Resources,
G.R.
No.
135385,
December
6,
2000
FACTS: Cruz, a noted constitutionalist, assailed the validity of
the RA 8371 or the Indigenous Peoples Rights Act on the
ground that the law amount to an unlawful deprivation of the
States ownership over lands of the public domain as well as
minerals and other natural resources therein, in violation of the
regalian doctrine embodied in Section 2, Article XII of the
Constitution. The IPRA law basically enumerates the rights of
the indigenous peoples over ancestral domains which may
include natural resources. Cruz et al content that, by providing
for an all-encompassing definition of ancestral domains and
ancestral lands which might even include private lands
found within said areas, Sections 3(a) and 3(b) of said law
violate
the
rights
of
private
landowners.
ISSUE: Whether or not the IPRA law is unconstitutional.
HELD: The SC deliberated upon the matter. After deliberation
they voted and reached a 7-7 vote. They deliberated again and
the same result transpired. Since there was no majority vote,
Cruzs petition was dismissed and the IPRA law was
sustained. Hence, ancestral domains may include natural
resources somehow against the regalian doctrine.
[G.R. No. 122269. September 30, 1999]REPUBLIC
vs. CA, ET. AL.,
FACTS:
The parcel of land that is presently the subject of the dispute in
the instant case Lot 3 Portion forms part of the abovementioned parcel of land declared by thisHonorable Court as
belonging to the public domain,classified/zonified land
available for fishpond development. This lot has been leased
to Mr. Porfirio Morado by theRepublic of the Philippines,
represented by theSecretary of Agriculture, for a period of 25
years, or upto December 31, 2013, under Fishpond
LeaseAgreement.On July 6, 1988, however, the late Zenaida
Bustria[daughter of Isidro Bustria] filed a complaint
againstPorfirio Morado in the Regional Trial Court of
Alaminos, Pangasinan for ownership and possessionover the
lot in question. Herein petitioner, the Republicof the
Philippines, was not made a party to that suit.In her complaint,
Zenaida Bustria claimed absoluteownership and quiet and
peaceful possession of several lots under PSU-155696
surveyed in the nameof her father, Isidro Bustria. She further
asserted thatsaid Porfirio Morado maliciously applied for a
fishpondpermit with the Bureau of Fisheries and
AquaticResources over Lot 3 thereof (the subject lot), wellknowing that said lot had always been occupied,possessed and
worked by her and her predecessors-in-interest.Porfirio
Morado denied the allegations in thecomplaint, claiming that
the lot in question is part of the public domain which he
developed and convertedinto a fishpond. Due, however, to

Porfirio Moradosand his counsels failure to appear at the pretrial andsubsequent court hearings, the trial court
subsequentlydeclared
Porfirio
Morado
as
in
default.Respondent Judge rendered a decision declaring
theplaintiff as the exclusive and absolute owner of theland in
question. Petitioner (REPUBLIC), filed with theCA a petition
for the annulment of the trial courtsdecision. Petitioner
alleged that the land in question iswithin the
classified/zonified alienable and disposableland for fishpond
development and that since the landformed part of the public
domain, the BFAR has jurisdiction over its disposition in
accordance with P.D.No. 704, 4. CA rendered a decision
dismissing thepetition. Hence, this petition for review.The
judgment rendered in a case may be annulled onany of the
following grounds: (a) the judgment is voidfor want of
jurisdiction or for lack of due process of law; or (b) it was
obtained through extrinsic fraud. Thequestion in this case is
whether the decision of theRegional Trial Court is void on any
of these grounds.The preliminary question, however, is
whether thegovernment can bring such action even though it
wasnot a party to the action in which the decision soughtto be
annulled was rendered. We shall deal with thesequestions in
inverse order.

inalienable public land. The land involved in this case

wasclassified as public land suitable for fishpond
development.In controversies involving the disposition of
public land, theburden of overcoming the presumption of state

RULING:

Both parties agreed in one point that the

disputed land was a mangrove swamp. The respondent argued
that mangrove swamp are agricultural land but the petitioner
contended that it is a forestall land therefore not disposable.

First, is the question whether petitioner haspersonality to bring

the action below. To begin with, anaction to recover a parcel
of land is in personam. As such,it is binding only between the
parties thereto, as this Courtexplained in Ching v. Court of
Appeals , viz: An action to redeem, or to recover title to or
possession of, real property is not an action in rem or an action
against the whole world, like a land registration proceeding or
the probate of a will; it is anaction in personam, so much so
that a judgment therein is binding only upon the parties
properly impleaded and duly heard or given an opportunity
tobe heard. Actions in personam and actions in remdiffer in
that the former are directed against specific persons and seek
personal judgments, while the latter are directed against the
thing or property or status of a person and seek judgments
with respect thereto asagainst the whole world. An action to
recover a parcel of land is a real action but it is an action in
personam,for it binds a particular individual only although it
concerns the right to a tangible thing.The appellate court,
holding that the proceedings beforethe trial court werein
personam, ruled that since petitioner was not a party to Civil
Case No. A-1759, it is not a realparty-in-interest and,
therefore, has no personality to bringthe action for annulment
of the judgment rendered in thatcase.The appellate court is in
error. InIslamic Dawah Council of the Phils. v. Court of
Appeals,this Court held that aparty claiming ownership of a
parcel of land which is thesubject of foreclosure proceedings
has a sufficient interestto bring an action for annulment of the
judgment renderedin the foreclosure proceedings even though
it was not aparty in such proceedings. It was held:[A] person
need not be a party to the judgment sought to be annulled.
What is essential is that he can provehis allegation that the
judgment was obtained by theuse of fraud and collusion and
he would be adversely affected thereby.
Private respondents do not deny that Isidro Bustria, towhom
they trace their ownership, previously filed afishpond
application with the BFAR over the disputed land.Neither do
they deny that the disputed land formed part of the public
domain.We agree with petitioner. The State clearly stands to
beadversely affected by the trial courts disposition of

ownershipof lands of the public domain lies upon the private

REMEDIAL LAW REVIEW ICASE DIGESTS
THE DIRECTOR OF FORESTRY VS. VILLAREAL
9/10/2014 0 Comments
Facts:
The petitioner, Director of Forestry was one of
the several persons who opposed the application for
registration of a parcel land classified as mangrove swamps in
the municipality of Sapian, Capiz with an area of 178,113
square meters of mangrove swamps, to the applicant Ruperto
Villareal.
He alleged that he and his predecessors-ininterests had been in possession of the said parcel of land for
more than forty years (40).

The Court of the First Instance of Capiz

however grants the application of the respondent. The decision
of the lower court was later affirmed by the Court of Appeals.
Hence the Director of Forestry elevated the case to the
Supreme Court for review on certiorari.
Issue:
Whether or not, mangrove swamps are
agricultural land or forest land.
Held:
The Supreme Court held that mangrove
swamps as forest lands is descriptive of its legal nature or
status and does not have to be descriptive of what the land
actually looks like.
Furthermore the legislative definition embodied
in section 1820 of the Revised Administrative Code of 1917
which declares that mangrove swamps or manglares form part
of the public forests of the Philippines hence they are not
alienable.
The evidence presented by the respondent in its
claim were not sufficient to prove its possession and
ownership of the land, he only presented tax declaration.
Wherefore the decision of the Court of Appeals
was set aside and the application for registration of title by the
respondent is dismissed by the Supreme Court.