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G.R. No.

L-32266; February 27, 1989




Ruperto Villareal applied for the registration of a land which consists of 178,113 square meters of
mangrove swamps located in the municipality of Sapian, Capizon on January 25, 1949, alleging that he
and his predecessors-in-interest had been in possession of the land for more than 40 years. He was
opposed by several persons, including the Director of Forestry on behalf of the Republic of the
Philippines. After trial, the application was approved by the Court of First Instance. of Capiz. The decision
was affirmed by the Court of Appeals.The Director of Forestry then came to this Court in a petition for
review on certiorari claiming that the land in dispute was forestal in nature and not subject to private
appropriation. He asks that the registration be reversed.

Whether or not mangrove swamps form part of the public land.

Yes, mangrove swamps form part of the public land because of its 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:

Sec. 1820. Words and phrases defined. — For the purposes of this chapter, “public forest”
includes, except as otherwise specially indicated, all unreserved public land including nipa and mangrove
swamps and all forest reserves of whatever character. xxx

Hence, they are not alienable under the Constitution and are not susceptible of private ownership. 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 declarations. Therefore 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