Director of Forestry vs. Villareal | G.R. No.

L-32266 | 27 February 1989

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-in-interests had been in possession of the said parcel of land for more than forty years (40). Both
parties agreed in one point that the disputed land was a mangrove swamp. The respondent argued that mangrove
swamp is an agricultural land but the petitioner contended that it is a forest land therefore not disposable. 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.
RULING: 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.
Note: Not all cases all those classified by law as forest land should be considered, Our previous description of
the term in question as pertaining to our agricultural lands should be understood as covering only those lands
over which ownership had already vested before the Administrative Code of 1917 became effective. Such lands
could not be retroactively legislated as forest lands because this would be violative of a duly acquired property
right protected by the due process clause. So we ruled again only two months ago in Republic of the Philippines
vs. Court of Appeals, where the possession of the land in dispute commenced as early as 1909, before it was
much later classified as timberland.