G.R. No. L-24796 DIRECTOR OF FORESTRY vsHON. EMMANUEL M.

MUOZ
23 SCRA 1183 Civil Law Land Titles and Deeds Systems of Registration Prior to PD
1529 Spanish Titles
Pinagcamaligan Indo-Agro Development Corporation, Inc. (Piadeco) is a company engaged
in logging. It was given a Certificate of Private Woodland Registration so that it can operate
in a 72,000 hectare land. It also has a Titulo de Propriedad which it acquired in 1894 under
the Spanish regime.
In 1964, the NAWASA (National Water and Sewerage Authority) director ordered the
cancellation of Piadecos certificate because it encroached beyond what was allowed in the
certificate. It actually cut trees in the Angat and Marikina watershed area which was
prohibited. The lower court ruled in favor of Piadeco. Piadeco also had a settlement with
Nawasa. Piadeco sought to renew its certificate but it was denied by the Asst. Director of
Forestry. The latter ruled that the Spanish title is no longer recognized and should have
never been used to apply for a Certificate.
ISSUE: Whether or not Piadeco can claim ownership over the property.
HELD: No. The Spanish title it acquired cannot be used to register for another Certificate.
There should be no question now that Forestry Administrative Order 12-2 has the force and
effect of law. It was promulgated pursuant to law. Section 1817, Revised Administrative
Code, empowers the Bureau of Forestry, with the approval of the department head, to issue
regulations deemed expedient or necessary to secure the protection and conservation of
the public forests in such manner as to insure a continued supply of valuable timber and
other forest products for the future, and regulating the use and occupancy of the forests and
forest reserves, to the same end. Forestry Administrative Order 12-2 was recommended by
the Director of Forestry, and approved by the Secretary of Agriculture and Natural
Resources. It is no less a valid law. It is an administrative regulation germane to the objects
and purposes of the law. A rule shaped out by jurisprudence is that when Congress
authorized the promulgation of administrative rules and regulations to implement a given
legislation, [a]ll that is required is that the regulation should be germane to the objects and
purposes of the law; that the regulation be not in contradiction with it, but conform to the
standards that the law prescribes.

Republic vs Naguiat
Natural Resources and Environmental Laws
G.R. No. 134209; January 24, 2006
FACTS:
Celestina Naguiat filed an application for registration of title to four parcels of land located
in Panan, Botolan, Zambales. The applicant alleges that she is the owner of the said parcels
of land having acquired them by purchase from its previous owners and their predecessorsin-interest who have been in possession thereof for more than thirty (30) years; and that to
the best of her knowledge, said lots suffer no mortgage or encumbrance of whatever kind
nor is there any person having any interest, legal or equitable, or in possession thereof.
Petitioner Republic opposed on the ground that neither the applicant nor her predecessorsin interest have been in open, continuous, exclusive and notorious possession and
occupation of the lands in question since 12 June 1945 or prior thereto, considering the fact
that she has not established that the lands in question have been declassified from forest or
timber zone to alienable and disposable property.
ISSUE:
Did the areas in question cease to have the status of forest or other inalienable lands of the
public domain?
HELD:
No, the said areas are still classified as forest land.The issue of whether or not respondent
and her predecessors-in-interest have been in open, exclusive and continuous possession of
the parcels of land in question is of little moment. For, unclassified land cannot be acquired
by adverse occupation or possession; occupation thereof in the concept of owner, however
long, cannot ripen into private ownership and be registered as title.
A forested area classified as forest land of the public domain does not lose such
classification simply because loggers or settlers have stripped it of its forest cover. Parcels of
land classified as forest land may actually be covered with grass or planted to crops by
kaingin cultivators or other farmers. "Forest lands" do not have to be on mountains or in out
of the way places. The classification is merely descriptive of its legal nature or status and
does not have to be descriptive of what the land actually looks like.