2) DIRECTOR OF FORESTRY v. HON. EMMANUEL M.

MUOZ
G.R. No. L-24796, June 28, 1968

FACTS: These are two interrelated cases involving some 72,000 hectares of land located in the
municipalities of Angat, Norzagaray and San Jose del Monte, Bulacan, and in Antipolo and
Montalban, Rizal claimed to be owned by Pinagcamaligan Indo-Agro Development Corporation,
Inc. (Piadeco) as evidenced by Titulo de Propiedad No. 4136, dated April 25, 1894.

PIADECO asserts that the original owner of the subject land appearing on the title acquired his
rights over the property by prescription under Articles 4 and 5 of the Royal Decree of June 25,
1880.

Petitioners in the first case are government officials seeking to annul the order and writ of
execution issued by the CFI Bulacan allowing Piadeco to haul its logs in land in question. In the
second, it was Piadeco's turn question the authority and jurisdiction of therein government
officials to order the stoppage of logging operations, construction of the roads, among other
things, from Piadecos private woodland area.

Series of motions were made by both parties in the two cases from 1964 to 1966 until it finally
reached the high court for this 1968 disposition.

ISSUE: Is Piadecos Titulo de Propriedad No. 4136 dated April 28, 1894 an incontrovertible
evidence of its valid ownership to the subject land?

RULING: No. It is a well-embedded principle that private ownership of land must be proved not
only through the genuineness of title but also with a
clear identity of the land claimed.

The standing presumption is that land pertains to the State, and any person seeking to establish
ownership over land must conclusively show that he is the owner.

There was inconsistency in Piadecos claim to the coverage of the land in question as it was
claimed to be 72,000 hectares on some instance and 74, 000 hectares on some when this issue
on the Spanish title should have been settled years ago.

Royal Decree of June 25, 1880 authorizes adjustments of land by filing application with the
Direccion General de Administracin Civil within one year from the effectivity of the decree. The
original owner should have settled the exact coverage of the land at this point. Moreover, Maura
Law was published in the on April 1894. That decree required a second petition for adjustment
within six months from publication, for those who had not yet secured their titles at the time of
the publication of the law.

There being cloud to Piadecos claim, the Court did not give prima facie value to Piadeco's title.
It was not proclaimed that Piadeco is a private woodland owner for purpose of these proceedings.

The petition for certiorari and prohibition in the first case was granted; the petition of Piadeco for
injunction and prohibition was denied. Costs in both cases against Piadeco.