The Director of Forestry vs.

Villareal

GR No. L-32266

February 27, 1989

Cruz, J.

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 are agricultural land but the petitioner contended that it is a
forestall 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.

Held: 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.