G.R. No. L-15532; October 31, 1963
LUIS I. SANTIAGO, plaintiff-appellee, vs. BASILAN LUMBER COMPANY, defendant-appellant.

FACTS

The plaintiff, Luis I. Santiago, filed a complaint for damages against Basilan Lumber Company for trespass. He alleged that in November 1952, the defendant, without his knowledge or consent, entered his titled land in Maluso, Basilan City, conducted logging operations, destroyed his banca, and caused damage to the land. The defendant, in its answer, asserted special defenses including that the land belonged to the government, was subject to public land and forest laws, and that its operations were lawful under valid timber licenses.
The parties submitted a Stipulation of Facts. Key stipulations were that the defendant admitted cutting 66,000 board feet of timber from the plaintiff’s land in November 1952 without his consent; the land was privately registered under Transfer Certificate of Title No. T-190 in Santiago’s name; the title contained no reservation of timber rights to the government; the defendant held a timber license from the Bureau of Forestry; and the plaintiff’s land was not registered with the Bureau of Forestry as a private woodland. Based on this stipulation and memoranda, the trial court held the defendant liable and awarded damages for the timber, the destroyed banca, land damage, and attorney’s fees.

ISSUE

The core issue is whether the defendant-appellant, Basilan Lumber Company, is liable for damages for cutting timber from the plaintiff’s registered land, notwithstanding the plaintiff’s failure to register his title with the Director of Forestry as required by Section 1829 of the Revised Administrative Code.

RULING

Yes, the defendant is liable. The Supreme Court affirmed the trial court’s decision. The legal logic centers on the nature of registered land ownership and the correct interpretation of the forestry registration requirement. The Court held that ownership of a registered land under the Land Registration Act includes ownership of everything on its surface, pursuant to Article 437 of the New Civil Code. The defendant’s timber license, issued by the Bureau of Forestry, could not validly authorize operations on land already titled to a private individual.
The Court clarified that the plaintiff’s failure to register his titled land with the Director of Forestry under Section 1829 of the Revised Administrative Code did not divest him of ownership or transfer timber rights to the government. The sole legal consequence of non-registration, as provided under Section 266 of the National Internal Revenue Code, is that forestry charges may be collected by the government on forest products cut from such unregistered private land. This potential liability for charges is a matter between the government and the landowner (Santiago) and does not extinguish the owner’s right to the timber or his right to exclude others, as granted by Article 429 of the New Civil Code. The defendant’s unauthorized entry and logging constituted a clear violation of these property rights, making it liable for damages. The Court also found no merit in the defendant’s challenge to the damage award, as by agreeing to a decision on the pleadings and stipulation, the defendant was deemed to have admitted the factual allegations in the complaint regarding the claimed damages.