G.R. No. L-24796 & L-25459, June 28, 1968
Case Parties:

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,
vs.
HON. EMMANUEL M. MUÑOZ, 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
PINAGCAMALIGAN INDO-AGRO DEVELOPMENT CORPORATION, INC., petitioner,
vs.
HON. MACARIO PERALTA, JR., in his capacity as the Secretary of National Defense; HON. ENETERIO DE JESUS, in his capacity as Undersecretary of National Defense; GENERAL RIGOBERTO ATIENZA, in his capacity as the Chief of Staff; Armed Forces of the Philippines, COLONEL MANUEL V. REYES, in his capacity as the Judge Advocate General, Armed Forces of the Philippines; and the TASK FORCES COMMANDER, Task Force Preserve (Tabak Division), 1st Infantry Division, Fort Magsaysay, Nueva Ecija, respondents.

FACTS

1. Pinagcamaligan Indo-Agro Development Corporation, Inc. (PIADECO) claimed ownership of about 72,000 hectares of land in Bulacan and Rizal based on Titulo de Propiedad No. 4136 dated April 25, 1894, and a deed of sale.
2. The Bureau of Forestry issued PIADECO Certificate of Private Woodland Registration No. PWR 2065-New on December 4, 1963, covering 4,400 hectares, expiring December 31, 1964. PIADECO conducted logging operations under this certificate.
3. On April 11, 1964, the Acting Director of Forestry cancelled PWR No. 2065-New, citing violations of forestry rules for cutting trees within the Angat and Marikina Watershed Reservations, which were excluded from the certificate. The Forest Station Warden also directed PIADECO to desist from operations.
4. PIADECO filed a petition for certiorari and prohibition with preliminary injunction in the Court of First Instance of Bulacan against the forestry officials and NAWASA (which had revoked a right-of-way grant). The court granted a preliminary injunction.
5. The forestry officials were declared in default for failure to answer timely. Their motions to set aside the default were denied.
6. On December 29, 1964, the lower court rendered judgment, making the injunction permanent. It found PIADECO to be the owner, that its operations were not in violation of rules, and cited Nawasa Resolution 1050 permitting selective logging upon payment.
7. PIADECO’s application for renewal of its certificate was denied on January 12, 1965, as its title was deemed not registerable under new forestry rules.
8. Following a presidential directive to stop illegal logging, the Armed Forces were deputized and seized logs cut by PIADECO.
9. PIADECO sought and obtained a writ of execution from the Bulacan court to haul its logs. The government officials then filed the present certiorari and prohibition case (L-24796) to annul the order and writ of execution. PIADECO filed a separate action (L-25459) to prohibit the military officials from stopping its operations.

ISSUE

The core legal issue is whether the Court of First Instance of Bulacan had jurisdiction to issue the writ of execution enforcing its judgment that allowed PIADECO to conduct logging operations and haul logs, despite the cancellation and non-renewal of its forestry registration certificate and the subsequent seizure of logs by deputized military authorities for alleged violations of forest laws.

RULING

The Supreme Court ruled in favor of the government petitioners and against PIADECO.
1. Lack of Jurisdiction of the Lower Court: The Supreme Court held that the Court of First Instance of Bulacan acted without jurisdiction. The subject matter of the case—the cancellation of a private woodland registration certificate and the enforcement of forestry laws—involved public right and fell within the primary jurisdiction of the Director of Forestry. The courts cannot interfere with the exercise of administrative discretion by forestry officials in the absence of grave abuse of discretion. The lower court’s judgment and subsequent writ of execution encroached upon this administrative domain.
2. Validity of Titulo de Propiedad No. 4136: The Court examined the title and found it spurious. It was not a genuine “titulo de propiedad” issued under the Spanish Mortgage Law but appeared to be a “composicion con el estado” title. Even if genuine, such titles were subject to verification and confirmation by the government, and the area claimed (72,000 hectares) was excessively large and improbable under Spanish law, which limited acquisitions to 1,000 hectares. The title could not vest absolute ownership without state confirmation.
3. Nature of Private Woodland Registration: The certificate issued to PIADECO was a permit, not a property right. It was subject to forestry laws, rules, and the regulatory power of the Director of Forestry. Its cancellation for violations was within the Director’s authority. The non-renewal was justified as the title was not registerable under the new forestry rules.
4. Authority of Military Officials: The deputization of the Armed Forces by the Secretary of Agriculture and Natural Resources to assist in enforcing forest laws and protecting forests was valid. The seizure of logs cut in violation of laws, especially within watershed reservations crucial for Manila’s water supply, was a legitimate exercise of police power and the state’s duty to conserve natural resources.
5. Finality of Judgment Does Not Confer Legality: The fact that the lower court’s judgment had become final did not make it valid if it was rendered without jurisdiction. A void judgment can be challenged at any time.
Disposition: The Supreme Court granted the petition in G.R. No. L-24796, annulling and setting aside the lower court’s orders and writ of execution. The petition in G.R. No. L-25459 was dismissed. Costs were imposed on PIADECO.