HONEY JOY B.

Heirs of Jose Amunategui vs Director of Forestry - Digest

Roque Borre filed an application for confirmation of imperfect title before the CFI. The heirs opposed this and
prayed that the title therefor be granted to them. The Director of Forestry opposed this saying that the parcel of
land sought to be registered was a mangrove swamp which is classified as forest land. Borre sold the land to
Bereber. CFI granted the application to Bereber.

Upon appeal to CA, the said court ruled that the land was a forest land, inalienable, hence cannot be owned by
private persons. A petition for certiorari was filed before the Supreme Court--the heirs argued that:
 Even though it is a mangrove swamp, there were no trees in the area which would make it a forest
 Even though it is a public forest land, it is still subject to land registration proceedings because the property
had been in actual possession of private persons for many years--which made it private land

The Supreme Court resolved the issue of whether or not the parcel of land is public forest land, not capable of
registration in the names of private applicants.

The Court held that:

 The land is a public forest land
 A forested area classified as forest land of the public domain does not lose such classification simply
because loggers or settlers may be stripped it of its forest cover. The classification is descriptive of its
legal nature or status and does not have to be descriptive of what the land actually looks like.
 Unless and until the land classified as forest is released in an official proclamation to that effect so that
it may form part of the disposable agri lands of public domain, the rules on confirmation of imperfect
title do not apply. A positive act of Government is needed to declassify land which is classified as
forest and to convert it into alienable or disposable land for agricultural or other purposes
 The only exception to this is where the land should have been in the possession of an occupant and
his predecessor in interest since time immemorial, for such possession would justify the presumption
that the land had never been part of the public domain.
 Here there was no evidence to show that they had possessed the land since time immemorial. What
the evidence showed was that their predecessor even applied for timber licenses to cut down trees in
the parcel of land.
 The statute of limitations with regard to public land does not operate against the State, unless the
occupant can prove possession and occupation of the same under claim of ownership for the required
number of years to constitute a grant from the state.

Sta. Rosa Corp vs CA

Sta. Rosa Corp owns a land in Barangay Casile, Cabuyao, Laguna. This contains watersheds. Petitioner filed an
ejectment case against the occupants (respondents) in the land . Meanwhile, the respondents petitioned the DAR
for compulsory acquisition of this land under CARP. After investigation and after the DARAB hearing, the
respondents’ petition for CARP coverage was granted. Petitioner appealed before CA which affirmed DARAB’s
decision.

The issue was whether or not the Sta Rosa Corp property could be acquired under CARP.