GR 29956; (May, 1981) (Digest)
G.R. No. L-29956 May 5, 1981
THE DIRECTOR OF FORESTRY, HON. TEOFILO SANTOS and THE DISTRICT FORESTER, Mr. AMBROCIO JUINIO, petitioners, vs. JUDGE MARIANO V. BENEDICTO, Presiding Judge of Branch V, Court of First Instance of Nueva Ecija and THE NEW TIMBERLAND CORPORATION, represented by NICANOR ABES, respondents.
FACTS
The New Timberland Corporation filed an action for injunction in the Court of First Instance of Nueva Ecija to restrain the Director of Forestry and the District Forester from interfering with its logging operations and to recover possession of 417 pieces of logs it had cut. The corporation claimed it operated based on a proposed timber license. Petitioners opposed the injunction, arguing the court lacked jurisdiction, the corporation had no cause of action as its proposed license was disapproved by the Secretary of Agriculture and Natural Resources, and administrative remedies were not exhausted.
It was established that the corporation cut and hauled the logs without a valid license, as the proposed license was never approved by the Secretary of Agriculture and Natural Resources. The Secretary formally disapproved the proposed license on July 2, 1968. Despite this, respondent Judge Benedicto rendered a decision declaring the logs were legally cut, ordering payment of forest charges, but prohibiting further cutting due to the license cancellation.
ISSUE
Whether the New Timberland Corporation had a legal right to cut the logs and possess them without a timber license approved by the Secretary of Agriculture and Natural Resources.
RULING
The Supreme Court reversed the lower court’s decision and dismissed the petition for injunction. The legal logic is anchored on the constitutional mandate for the conservation of natural resources and the specific regulatory framework governing timber licenses. Under Forestry Administrative Order No. 11, Section 14, a timber license for cutting 1,000 cubic meters or more requires the approval of the Secretary of Agriculture and Natural Resources. The Director of Forestry’s power to issue licenses is subject to the control of the Department Secretary.
The proposed license here was merely submitted to the Secretary for approval and was subsequently disapproved. Consequently, no valid license was ever issued. The cutting of the logs without this requisite approval was unauthorized and illegal. The corporation, therefore, acquired no right to possess the forest products. The Court, citing Director of Forestry v. Muñoz, emphasized the public policy of forest preservation and the judiciary’s duty to scrutinize claims to forest resources rigorously. The defense of good faith is unavailing against the State’s ownership and regulatory authority over natural resources. The logs, being illegally cut, belong to the State.