The principal document presented by petitioners to prove the private character of the Lot is the Certification of the Bureau of Forest Development dated March 18, 1986 that the Lot is excluded from the Marikina Watershed (Exh. 141, as amended, otherwise known as the Public Land Act, which prescribes the substantive as well as the procedural requirements for acquisition of public lands. Petitioners further contend that town sites are considered alienable and disposable under CA 141. They likewise opposed the registration and asserted that the Lot, which is situated inside the Marikina Watershed Reservation, is inalienable. Stewardship as an alternative to land ownership in the Philippine uplands, Philippines Univ., Los Banos, College, Laguna (Philippines). The land registration court rendered its decision on January 30, 1991 and the Solicitor General received a copy of the decision on April 23, 1991.41 Petitioners point out that the Solicitor General filed with the Court of Appeals the petition for annulment of judgment invoking Section 9(2) of BP Blg. No. ), Application of silvicultural programs such as timber stand improvement and assisted natural regeneration. Certificate of Stewardship - Department of Environment Comments will be considered as part of the next review process. 7 0 obj Moreover, petitioners further point out that the Solicitor General filed the petition for annulment after the land registration court issued its order of May 6, 1991 directing the Land Registration Authority to issue the corresponding decree of registration. Petitioners do not claim to have documentary title over the Lot. Stewardship projects are created through an open, collaborative process that involved local communities and interested organizations. The exceptions are some areas where CSC is not generally acceptable such as in the Cordilleras, in predominantly Muslim areas in Mindanao, "Stewardship as an alternative to land ownership in the Philippine uplands"@eng, Philippines Univ., Los Banos, College, Laguna (Philippines). She has a right or interest to protect as she was the one dispossessed and thus, she can file the action for forcible entry. DENR ADMINISTRATIVE ORDER NO - FAO Aware that the parcels of land which their forefathers had occupied, developed and tilled belong to the Government, they filed a petition with then President Corazon C. Aquino and then DENR Secretary Fulgencio S. Factoran, to award the parcels of land to them. REPUBLIC OF THE PHILIPPINES WebThe Marine Stewardship Council (MSC) is responsible for these requirements. WebSans the presence of the awardee of the Certificate of Stewardship, the provision clearly allows Valeriana to institute the action for the recovery of the physical possession of the property against the alleged usurper. The Court of Appeals explained thus: "Under the Regalian Doctrine, which is enshrined in the 1935 (Art. In a motion dated April 5, 1991, received by the Solicitor General on April 6, 1991, petitioners alleged that the decision dated January 30, 1991 confirming their title had become final after the Solicitor General received a copy of the decision on February 18, 1991. Hence, the court again issued an order submitting the case for decision based on the evidence of the petitioners. SP No. Pasigarbo sa Larena Christmas Tree Decorating Contest-Season 3. No. Iowa The University of the Philippines (UP) is the countrys national university. 6 Consolidated Rejoinder, pp. Any watershed or any area of land adjacent to any surface water or overlying any ground water may be declared by the Department of Natural Resources as a protected area. There was a fraud case where some group of people tried to sell forestland under Certificates of Stewardship Contracts (CSCs) by means of &q Protocol Plate Number 1 is issued to the President 2 to the Vice President 3 to the Senate president 4 to the House speaker 5 to the Its the employees responsibility to follow the company policy including notice period on severance regardless of the reason. On August 6, 1991, the Solicitor General filed with the Court of Appeals a Petition for Annulment of Judgment pursuant to Section 9(2) of BP Blg. ( %dhi9hklfrp25 Forestry Development Center. This non-regulatory In case the resources were planted through the project involving the CBFM-PO, the proceeds shall be subjected to the agreed benefit-sharing mechanisms. Upon recommendation of the Secretary of Agriculture and Natural Resources and pursuant to the authority vested in me by law, I, FERDINAND E. MARCOS, President of the Philippines, do hereby, exclude from the operation of Executive Order No. In Republic vs. De los Angeles,44 which involved the registration of public lands, specifically parts of the sea, the Court rejected the principle of res judicata and estoppel to silence the Republics claim over public lands. It's a privately held company. Legal Considerations for Stewardship Funding My licensed expired. The law governed the disposition of lands of the public domain. In most cases, this proof of purchase will be an invoice, but First Issue: whether petitioners have registrable title over the Lot. PENRO Negros Oriental Coastal Clean-up 2022, Special Service Award for Forester Filadelfo Jumawid, Kababayen-an Para sa Kinaiyahan: Women Take the Lead in the Assessment of Typhoon-Damaged Mangroves of Bohol, PENRO Siquijor celebrates the International Day of Forest, CENRO Talibon joins the International Coastal Cleanup, PENRO Cebu Celebrates International Earth Day 2022, 82nd Anniversary of Siquijor Forest Reserve, PENRO Siquijor Coastal Clean-up In celebration of the Month of the Planet Earth, Certificate of Wildlife Registration (CWR), FORESHORE APPLICATION (FLA) OR MISCELLANEOUS LEASE APPLICATION (MLA). We quote the pertinent portions of the courts decision, as follows: "From the evidence presented, the Court finds that from the testimony of the witnesses presented by the Applicants, the property applied for is in actual, open, public and notorious possession by the applicants and their predecessor-in-interest since time immemorial and said possession had been testified to by witnesses Jimmy Torres, Mariano Leyva, Sergio Montealegre, Jose Amo and one Chona who were all cross-examined by Counsel for Oppositor Republic of the Philippines. No. The case law does not support this submission. However, shortly after the filing of their opposition, intervenors learned that the land registration court had already rendered a decision on January 30, 1991 confirming petitioners imperfect title. The CS is an agreement entered into by and between the government and individuals/families actually occupying or tilling portions of the forestlands covered with Community-Based Forest Management (CBFM) Agreement. The study also revealed such other problems as: continued opening/occupancy of forest areas not originally covered by the December 1981 cut-off date and those excluded in the ISFP, political interference, inadequate or lack of skilled manpower to provide technical assistance and related services to the CSC recipients. Mangrove Stewardship CertificateUnder the Mangrove Stewardship Program, the grantor is issued a Certificate of Stewardship allowing the grantee to plant and/or manage and protect permanent mangrove forest for coastline protection and support of coastal fisheries and to sustainably harvest and enjoy all the produce therefrom. Subsequently, then President Aquino issued Proclamation No. contract is signed for the audit. } !1AQa"q2#BR$3br ( Company Information CTRP 1 or Tax Reform for Acceleration and Inclusion (TRAIN) Package 1A is already signed into a law even though there are opposing consumer he contents in this blog are not provided to serve as legal, tax, or investment advice. The 1987 Constitution readopted this policy. The exceptions are some areas where CSC is not generally acceptable such as in the Cordilleras, in predominantly Muslim areas in Mindanao, and where there are existing petitions that lands currently occupied be released as alienable and disposable. Population growth and industrialization have taken a heavy toll on the environment. 1. According to the Solicitor General, he received on April 23, 1991 a copy of the land registration courts decision dated January 30, 1991, and not on February 18, 1991 as alleged by petitioners in their motion. This technical description categorically stated that the Lot "is inside IN-12 Mariquina Watershed.". Additional owners BERNARDINA TAWAS, JORETO TORRES, JOSE AMO, VICENTE TORRES and SERGIO MONTEALEGRE who bought portions of the property from Edna Collado through a Deed of Sale on 6 November 1985 (Exhibit "Q" to "Q-3"). endobj WebCertificate of Stewardship is awarded to individuals or families actually occupying or tilling portions of forest lands pursuant to LOI 1260 for a period of 25 years renewable for All proceedings of the land registration court involving the Lot are therefore null and void. 8. 5 0 obj endstream According to intervenors, they are the actual occupants of the Lot which petitioners sought to register. 141, as amended, is enough to vest upon petitioner Gordula the "private rights" recognized and respected in Proclamation No. Licenses are non-transferable. The same, however, has already been amended by Presidential Decree No. Petitioners fault the Court of Appeals for giving due course to the Republics petition for annulment of judgment which was filed long after the decision of the land registration court had allegedly become final and executory. There is no proof that prior to the issuance of EO 33 in 1904, petitioners had acquired ownership or title to the Lot either by deed or by any other mode of acquisition from the State, as for instance by acquisitive prescription. Secure .gov websites use HTTPS 11 Republic vs. Sayo, 191 SCRA 71 (1990). This Stewardship Agreement shall form an integral part of the Certificate of Stewardship. Thus, it is plain error for petitioners to argue that under the Philippine Bill of 1902 and Public Land Act No. /Type /Page ( After appraisal of the evidence submitted by petitioners, the land registration court held that petitioners had adduced sufficient evidence to establish their registrable rights over the Lot. 14 AND 16, BOTH SERIES OF 1915, WHICH ESTABLISHED THE WATERSHED RESERVATION SITUATED IN THE MUNICIPALITY OF ANTIPOLO, PROVINCE OF RIZAL, ISLAND OF LUZON, A CERTAIN PORTION OF THE LAND EMBRACED THEREIN AND RESERVING THE SAME, TOGETHER WITH THE ADJACENT PARCEL OF LAND OF THE PUBLIC DOMAIN, FOR TOWNSITE PURPOSES UNDER THE PROVISIONS OF CHAPTER XI OF THE PUBLIC LAND ACT. The Republic of the Philippines, through the Solicitor General, and the Municipality of Antipolo, through its Municipal Attorney and the Provincial Fiscal of Rizal, filed oppositions to petitioners application. 926, the first Public Land Act, which was described as follows: "Act No. WebCertificate of Stewardship Contract (CSC), is awarded to individuals or families occupying or tilling portions of forestland, for up to a maximum of 5 ha, and has 25 plus 25 years duration. Thus, in Mago the Court held that: "It is quite clear and patent that the motions for intervention filed by the movants at this stage of the proceedings where trial had already been concluded x x x and on appeal x x x the same affirmed by the Court of Appeals and the instant petition for certiorari to review said judgment is already submitted for decision by the Supreme Court, are obviously and, manifestly late, beyond the period prescribed under x x x Section 2, Rule 12 of the rules of Court. ( Petitioners contend that Proclamation No. Rule 19 of the 1997 Rules of Civil Procedure47 provides in pertinent parts: Section 1. Who may intervene. This verification is made upon the request of the Chief, Legal Staff, R-4 as contained in his internal memorandum dated March 18, 1986. Certificate of Stewardship Definition | Law Insider 573, should not be interpreted as requiring a title. EDNA COLLADO bought the property from Myrna Torres in a Deed of Sale dated 28 April 1984 (Exhibit "P-1" to "P-3"). An applicant for confirmation of imperfect title bears the burden of proving that he meets the requirements of Section 48 of CA 141, as amended. On August 14, 1991, intervenors filed a motion to vacate judgment and for new trial before the land registration court.