Pinagcamaligan Indo-Agro Development Corporation vs Macario Peralta, Jr.

February 1, 2012

Note: This case is consolidated with G.R. No. L-24796 DIRECTOR OF FORESTRY  vs HON. EMMANUEL M. MUÑOZ       

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 Piadeco’s 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.”


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