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.
28) GODOFREDO NAVERA v. HON. PERFECTO QUICHO
G.R. No. L-18339, June 29, 1962

FACTS: Municipality of Ligao filed for a petition under Section 112 of Act No. 496 with the CFI
of Albay for the correction of Transfer Certificate of Title No. T-9304 issued in the name of
Godofredo Navera, covering Lot No. 2793-A, on the ground that a portion of 123 sq. m. of
Natera Street was erroneously included in said title, as testified by a duly licensed surveyor,
during the cadastral survey of Ligao.

A motion to dismiss was filed by herein petitioner Navera on the ground that the relief sought
by the Municipality of Ligao cannot be granted under Section 112 of Act 496 because the same
would involve the opening of the original decree of registration and that this cannot be done at
this stage after the lapse of 23 years from the issuance of the certificate of title. Alleging further
that the petition does not seek merely the correction of a mistake or error but the return or
reconveyance of a portion of a registered property to respondent.

The lower court ruled in favor of the Municipality of Ligao, thus this case.

ISSUE: Is the Municipality of Ligao correct in invoking Section 112 of Act No. 496 to correct the
error in Transfer Certificate of Title No. T-9304?

RULING: No. It is true that the erroneous inclusion of the 123 sq. m. of Natera street in the
title issued to petitioner may be corrected under Section 112 of Act 496 because under the law,
a person who obtains a title which includes by mistake a land which cannot legally be registered
does not by virtue of such inclusion become the owner of the land erroneously included therein.

But this theory only holds true if there is no dispute that the portion to be excluded is really
part of a public highway. This principle only applies if there is unanimity as to the issue of fact
involved.

Lacking the unanimity required under said law since the claim of the municipality that an error
has been committed in the survey of the lot is not agreed to by petitioner, the petition cannot
be granted under Section 112 of Act No. 496.

The petition is granted and the previous orders of respondent court were set aside. No costs.