Case Digest (G.R. No. L-24796)
Facts:
Director of Forestry, Forest Station Warden, District 13, Bureau of Forestry, Board of Directors, National Waterworks and Sewerage Authority and Chief of Staff, Armed Forces of the Philippines, Petitioners v. Hon. Emmanuel M. Munoz, as Judge of the Court of First Instance of Bulacan, Branch I, the Sheriff of the Province of Bulacan, and Pinagcamaligan Indo‑Agro Development Corporation, Inc., Respondents; and consolidated Pinagcamaligan Indo‑Agro Development Corporation, Inc., Petitioner v. Hon. Macario Peralta, Jr., Secretary of National Defense, et al., Respondents, G.R. Nos. L‑24796 & L‑25459, June 28, 1968, the Supreme Court En Banc, Sanchez, J., writing for the Court.The dispute arises from logging operations by Pinagcamaligan Indo‑Agro Development Corporation, Inc. (Piadeco) over lands it claims (72,000–74,000 ha) in Bulacan and Rizal. Piadeco presented a Spanish‑era grant, Titulo de Propiedad No. 4136 (dated April 1894) and obtained from the Bureau of Forestry a Certificate of Private Woodland Registration PWR 2065‑New on December 4, 1963 covering about 4,400 ha (to expire December 31, 1964). Piadeco proceeded to log under that certificate.
On April 11–14, 1964 the Acting Director of Forestry cancelled PWR 2065‑New for alleged violations (cutting within Angat and Marikina watershed reservations). The Forest Station Warden directed Piadeco to desist and not to remove unscaled logs. Piadeco filed Civil Case No. 3035‑M in the Court of First Instance (CFI) of Bulacan seeking certiorari, prohibition and preliminary injunction; the CFI issued an injunction on May 4, 1964, later dissolved for government damage (May 14, 1964) but the forestry officials were declared in default (July 13, 1964) after unsuccessful attempts to set aside the default. Piadeco submitted ex parte evidence; on December 29, 1964 the CFI ruled for Piadeco (finding ownership, no violation of forestry rules, and reinstated the injunction permanently), and approved Piadeco’s compromise with NAWASA.
Piadeco applied to renew PWR 2065‑New on December 28, 1964; renewal was denied on January 12, 1965 (Assistant Director Utleg), and the certificate expired December 31, 1964. Amid national concern over illegal logging the President on March 8, 1965 directed a stop to illegal logging and the Secretary of Agriculture and Natural Resources asked the Secretary of National Defense to detail AFP units as deputized agents of the Bureau of Forestry. Task forces impounded Piadeco’s logs.
Piadeco sought ex parte execution (May 11, 1965) of the December 29, 1964 judgment; after withdrawal and refiling, Judge Munoz granted a writ of execution on June 1, 1965 and a writ issued June 3, 1965 directing the sheriff to permit hauling. Forestry officials and the Armed Forces refused to allow hauling; Piadeco moved for contempt. The CFI on July 8, 1965 ordered that Piadeco’s property remains registered subject to renewal and directed forestry officials and Army personnel to allow hauling, relying in part on a June 7, 1965 certification by Assistant Director Utleg.
The Director of Forestry, Forest Warden and the AFP Chief of Staff filed original petitions with the Supreme Court (L‑24796) for certiorari and prohibition to annul the CFI’s June 1, June 3 and July 8, 1965 execution orders; this Court issued a preliminary injunction July 30, 1965 and later allowed the Solicitor General to remove the impounded logs to the Engineer Corps for safekeeping pending final resolution. Piadeco separately filed an original petition (L‑25459) for injunction and prohibition against Defense and AFP officials to prevent them from stopping its logging; that petition for preliminary injunction was denied December 31, 1965 and on reconsideration February 1, 1966.
The Supreme Court considered, in...(Subscriber-Only)
Issues:
- Is Piadeco’s Spanish‑era Titulo de Propiedad No. 4136 registrable under Section 1829, Revised Administrative Code and Forestry Administrative Order 12‑2?
- Was the cancellation of PWR 2065‑New, the seizure/impoundment of Piadeco’s logs, and the refusal to permit hauling lawful under applicable forestry regulations and tax law?
- Should Piadeco’s petition for injunction and prohibition (L‑25459) against Defense and Armed Forces officials be granted to a...(Subscriber-Only)
Ruling:
- (Subscriber-Only)
Ratio:
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Doctrine:
- (Subscriber-Only)