is certificate of stewardship contract transferable

Featured Projects Learn about successful local BLM projects implemented through stewardship contracting. Petitioners prayed that the land registration court order the Land Registration Authority to issue the necessary decree in their favor 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). The NCIP shall conduct a study of other tenurial instruments issued to members of ICC/IP communities such as, but not limited to, Certificates of Land Ownership Awards (CLOA) of the Department of Agrarian Reform (DAR), and Certificate of Stewardship Contracts (CSC) of the DENR, in order to determine the feasibility of their conversion to CADTs or CALTs, and the case may be. Upon recommendation of the Secretary of Environment and Natural Resources and pursuant to the authority vested in me by law, I, CORAZON C. AQUINO, President of the Philippines, do hereby exclude from the operation of Executive Order No. endobj WebThis paper examines the problems and issues in the granting and in the consequent acceptance of the certificate of stewardship contract (CSC). /Contents 5 0 R Watershed Reservation is a Natural Resource, The term "natural resource" includes "not only timber, gas, oil coal, minerals, lakes, and submerged lands, but also, features which supply a human need and contribute to the health, welfare, and benefit of a community, and are essential to the well-being thereof and proper enjoyment of property devoted to park and recreational purposes."26. That the land in question is within the Marikina Watershed Reservation is confirmed by the Administrator of the National Land Titles and Deeds in a Report, dated March 2, 1988, submitted to the respondent Court in LR Case No. The Casile and Kabanga-an watersheds can be considered a most vital life support system to thousands of inhabitants directly and indirectly affected by it. >> (. 6657 (Comprehensive Agrarian Reform law of 1988) states, "No reclassification of forest or mineral lands to agricultural lands shall be undertaken after the approval of this Act until Congress, taking into account ecological, developmental and equity considerations, shall have delimited by law, the specific limits of the public domain.". In Sta. Site are non-transferable. PEPEPEPEPEPEPEPEPEPEPEPEPEPEPEPEPE!8 QE QE QE QE QE QE QE QE QE QE QE QE QE QE QE QE QE QE QE QE QE QE QE QE QE QE QE QE QE QE QE QE QE QE QE QE QE QE QE QE QE QE q-PEPEPEPEPEPEPEPEP( ( To be sure, the Court of Appeals did not pass upon the actual status of intervenors in relation to the Lot as this was not in issue. No. Rules and Regulations may be promulgated by such Department to prohibit or control such activities by the owners or occupants thereof within the protected area which may damage or cause the deterioration of the surface water or ground water or interfere with the investigation, use, control, protection, management or administration of such waters.". /Im1 Do 4 Co-petitioners Bernardina Tawas, Joseto C. Torres, Jose Amo, Sergio L. Montealegre and Vicente C. Torres. Type of Benefits - Social Security System (SSS). Unless the pernicious agricultural activities of the Casile farmers are immediately stopped, it would not be long before these watersheds would cease to be of value. 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. ( (Heirs of Gumangan vs. Court of Appeals. PO Resolution requesting the DENR through the CENRO for the issuance of the CS with the following attachments: Community Environment and Natural Resources Office (CENRO), Actual tillers or cultivators of the land to be allocated, Member of the Peoples Organization which was granted a CBFM area subject to the CS application, Willing to develop the land as well as participate in CBFM activities, Not a previous holder of CS that was cancelled for a cause, Agreement on the rights and responsibilities of CS holders, Individual application for CS of prospective beneficiaries, duly endorsed by the PO head, Community map (parcellary map) of the area showing parcels actually occupied and/or cultivated by individual families, properly numbered, and validated in the general meeting, Possess, occupy, develop, protect, manage and utilize forestlands and its resources in accordance with the ratified CRMF, and appropriate methods and practices, and such other rights as may be granted by law. 10 Issued by Governor Luke E. Wright pursuant to the provisions of Act Numbered Six Hundred and Forty-Eight (Act No. We also hold that environmental consequences in this case override concerns over technicalities and rules of procedure. A parcel of land (Lot B of Proposed Poor Mans Baguio, being a portion of alienable and disposable portion of public domain) situated in the municipality of Antipolo, Province of Rizal, Island of Luzon. The University of the Philippines (UP) is the countrys national university. Certificate of Limited Partnership means the Certificate of Limited Partnership of the Partnership filed with the Secretary of State of the State of Delaware as referenced in Section 7.2, as such Certificate of Limited Partnership may be amended, supplemented or restated from time to time. ( Third, Gordula vs. Court of Appeals33 is in point. 285-287. WILDLIFE APPLICATION REQUIREMENTS (Please Click for Online Application), TREE CUTTING PERMIT (Please Click for Online Application), PROTECTED AREA COMMUNITY-BASED RESOURCE MANAGEMENT AGREEMENT(PACBRMA), COMMUNITY BASED FOREST MANAGEMENT AGREEMENT (CBFMA) & CERTIFICATE OF STEWARDSHIP CONTRACT (CSC), Socialized Industrial Forest Management Agreement (SIFMA), INDUSTRIAL FOREST MANAGEMENT ANGREEMENT (IFMA). Section 48 (b) of CA 141, as amended, applies exclusively to alienable and disposable public agricultural land. All other lands covered and embraced under Executive Order No. 1283 promulgated on June 21, 1974 which established the Boso-boso Town Site Reservation, amended by Proclamation No. WebWhen their promise is secured by a mortgage that becomes due and payable in full upon transfer, the purchaser will not close without assurance that the stewardship payment 6. The law bars the ARBs to transfer the awarded land during a holding period of 10 years and that is while the amortization to the government has not yet been fully paid. It is only issued within established CBFM project with CBFMA, subject to the decision and recommendation of the PO. Has the right to nominate his/her heir to the Stewardship Agreement, to facilitate orderly transfer upon death or incapacity or change of vocation of the CS holder. XII, Sec. 269-A, LRC Rec. 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. ( These documents readily and effectively negate the allegation in private respondent Collados application that "said parcel of land known as Psu-162620 is not covered by any form of title, nor any public land application and are not within any government reservation (Par. N-191242 on April 4, 1986 in the name of Apolonia Garcia, et al., pursuant to the Decision and Order for Issuance of the Decree dated February 8, 1984 and March 6, 1984, respectively, and the remaining portion of plan Psu-162620 is inside IN-12, Marikina Watershed. However, the main thrust of petitioners claim over the Lot is that "all Presidential proclamations like the proclamation setting aside the Marikina Watershed Reservation are subject to private rights." Prepared for the Office of the United States Agency for International Development (USAID) under Contract Number 492-0444-C-00-5073-00 ( 12942 only on August 6, 1991, after the decision had supposedly become final and executory. Rosa Realty also recognized the need to protect watershed areas and took note of the report of the Ecosystems Research and Development Bureau (ERDB), a research arm of the DENR, regarding the environmental assessment of the Casile and Kabanga-an river watersheds involved in that case. It prescribed rules and regulations for the homesteading, selling and leasing of portions of the public domain of the Philippine Islands, and prescribed the terms and conditions to enable persons to perfect their titles to public lands in the Islands. In Director of Lands vs. Reyes, we held that a settler claiming the protection of "private rights" to exclude his land from a military or forest reservation must show "x x x by clear and convincing evidence that the property in question was acquired by [any] x x x means for the acquisition of public lands. 18 Noblejas & Noblejas, Registration of Land Titles and Deeds, 1992 Ed. ( ( In the case of Director of Lands vs. Reyes, 68 SCRA 193-195, by "private rights" means that applicant should show clear and convincing evidence that the property in question was acquired by applicants or their ancestors either by composition title from the Spanish government or by Possessory Information title, or any other means for the acquisition of public lands xxx" (underscoring supplied). A .gov website belongs to an official government organization in the United States. The Court shall consider whether or not the intervention will unduly delay or prejudice the adjudication of the rights of the original parties, and whether or not the inertvenors rights may be fully protected in a separate proceeding. All proceedings of the land registration court involving the Lot are therefore null and void. 926 was that the land possessed and claimed by individuals as their own are agricultural lands and therefore alienable and disposable. WebThe negotiable instrument, which is essentially a document embodying a right to the payment of money and which may be transferred from person to person, developed historically from efforts to make credit instruments transferable; that is, documents proving that somebody was in their debt were used by creditors to meet their own liabilities. He had the property resurveyed in his name on May 21-28, 1928 (Exhibit "X" and "X-1"; testimony of Mariano Leyva, a son of Diosdado Leyva). Davide, Jr., C.J., (Chairman), on official leave. 1. With the exception of agricultural, industrial or commercial, residential, and resettlement lands of the public domain, natural resources shall not be alienated, and no license, concession, or lease for the exploration, development, exploitation, or utilization of any of the natural resources shall be granted for a period not exceeding twenty-five years, renewable for not more than twenty-five years, except as to water rights for irrigation, water supply, fisheries, or industrial uses other than the development of water power, in which cases beneficial use may be the measure and the limit of the grant. 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. The law governed the disposition of lands of the public domain. Secretary Factoran directed the Director of Forest Management Bureau to take steps for the segregation of the aforementioned area from the MWR for development under the DENRs ISF Programs. "Forest lands" do not have to be on mountains or in out of the way places. This Stewardship Agreement shall form an integral part of the Certificate of Stewardship. Rule 19 of the 1997 Rules of Civil Procedure47 provides in pertinent parts: Section 1. Who may intervene. The 1987 Constitution reaffirmed the Regalian doctrine in Section 2 of Article XII25 on "National Economy and Patrimony". This verification is made upon the request of the Chief, Legal Staff, R-4 as contained in his internal memorandum dated March 18, 1986. 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. WebStewardship Users of financial reports need information to help them assess managements stewardship. Download the BLM Stewardship Manual. 1637 excluded Lot A (of which the Lot claimed by petitioners is part) for townsite purposes and reverted it to MWR coverage.34 Proclamation No. During the hearing on January 9, 1991, only the assistant provincial prosecutor appeared without the Solicitor General. Note: All data are approximate and subject to change based on future survey. x x x, Clearing and tilling of the lands are totally inconsistent with sound watershed management. 263, Otherwise Known as the Community-based Forest Management Strategy (CBFMS), Guidelines on the Establishment of Community-based Forest Management (CBFM) Projects within Mangrove Areas, Amendments of DENR A.O. Current regulations allow the awarding of tenurial rights (25-year lease or forest management agreements issued by the DENR, i.e. x x x           x x x           x x x. >> 2 0 obj Hence, the court again issued an order submitting the case for decision based on the evidence of the petitioners. Section 16. 7 0 obj Learn about successful local BLM projects implemented through stewardship contracting. Certificate of Amendment has the meaning set forth in Section 2.1(a) of this Agreement. A strict application of the rules would blur this bigger, far more important picture. (Sgd) ARMENDO R. CRUZSupervising Cartographer, (Sgd) LUIS G. DACANAYChief, Forest Engineering & Infrastructure Section". The Court remanded the case to the Department of Agriculture and Adjudication Board or DARAB to re-evaluate and determine the nature of the parcels of land involved in order to resolve the issue of its coverage by the CARL. Under the Regalian Doctrine, all lands not otherwise appearing to be clearly within private ownership are presumed to belong to the State.11 The Spaniards first introduced the doctrine to the Philippines through the Laws of the Indies and the Royal Cedulas, specifically, Law 14, Title 12, Book 4 of the Novisima Recopilacion de Leyes de las Indias12 which laid the foundation that "all lands that were not acquired from the Government, either by purchase or by grant, belong to the public domain. WebThe Marine Stewardship Council (MSC) is responsible for these requirements. 96-29 which prescribes the Rules and Regulations for the Implementation of Executive Order No. Site are non-transferable. Their possession has been open, public, notorious and in the concept of owners. >> Other Programs: Stewardship contracting is not a replacement for the BLMs established timber sale or grazing programs. Prescription, both acquisitive and extinctive, does not run against the State. (Q@Q@Q@Q@Q@Q@Q@Q@Q@Q@Q@Q@Q@Q@Q@Q@Q@Q@Q@Q@Q@Q@Q@Q@Q@Q@Q@Q@Q@Q@Q@Q@Q@Q@Q@Q@Q@Q@Q@Q@Q@Q@Q@Q@Q@Q@Q@Q@Q@Q@Q@Q@Q@Q@Q@Q@Q@Q@Q@a *{pBES,( ( ( ( ( ( ( ( ( ( ( ( ( ( ( (6l%qs@ ( ( ( ( ( ( ( ( ( ( ( ( ( ( ( ( ( ( ( ( ( ( ( ( ( ( ( ( ( ( ( ( ( ( ( ( ( ( ( ( ( ( ( ( ( ( ( ( ( ( ( ( ( ( ( ( QE QE QE QE QE QE QE QE RE Z(E7Rn)aCRn(:P;SA=sHIKI@Q@EPEP0( ( ( ( ( ( ( ( ( ( ( ( ( ( ( ( ( ( ( ( ( ( J ( ( ( ( ( ( ( Kp; ZT#Fs$x O%QE PO Resolution with attached Census of forest land occupants; Agreed rights and responsibilities of CS holders; Individual application for CS of prospective beneficiaries; community map of the area showing the parcels actually occupied, properly numbered and validated in the general meeting. Both the 1935 and 1973 Constitutions prohibited the alienation of all natural resources except agricultural lands of the public domain. x x x Even assuming that petitioners did have the said properties surveyed even before the same was declared to be part of the Busol Forest Reservation, the fact remains that it was so converted into a forest reservation, thus it is with more reason that this action must fail. Notes: stewardship is not a ownership, so they have no rights to transfer or sell the land. ( WebCongress permanently authorized stewardship contracting through the 2014 Farm Bill, ensuring that the BLM will always have this valuable tool available. N-55948 and was issued Decree No. The SEP Clearance may be transferred as long as a document shall be submitted showing the transfer of ownership, operating agreements or rights over the project. To the mind of the Court, Applicants have presented sufficient evidence to establish registrable title over said property applied for by them. WebWhen their promise is secured by a mortgage that becomes due and payable in full upon transfer, the purchaser will not close without assurance that the stewardship payment secured by the mortgage has been, or will be, paid /Im1 7 0 R vs. The Court in Sta. 926, the first Public Land Act, was passed in pursuance of the provisions of the Philippine Bill of 1902. Section 4 (a) of RA No. This paper examines the problems and issues in the granting and in the consequent acceptance of the certificate of stewardship contract (CSC). ( Likewise, in a letter38 dated November 11, 1991, the Deputy Land Inspector, DENR, Region IV, Community Environment and Natural Resources Office, Antipolo, Rizal, similarly confirmed that the Lot is within the MWR. Petitioners contend that their claim of ownership goes all the way back to 1902, when their known predecessor-in-interest, Sesinando Leyva, laid claim and ownership over the Lot. Environmental degradation from unchecked human activities could wreak havoc on the lives of present and future generations. Done in the City of Manila, this 5th day of June, in the year of Our Lord, nineteen hundred and ninety. 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. /Length 6 0 R On March 24, 1986, petitioner Edna T. Collado filed an Amended Application to include additional co-applicants.4 Subsequently, more applicants joined (collectively referred to as "petitioners" for brevity).5. 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 Certificate of Conformance means a document issued by the NCWM based on testing by a participating laboratory that constitutes evidence of conformance of a type. 2004-29; DENR Administrative Order No. In the meantime, on May 7, 1991, the land registration court issued an order directing the Land Regulation Authority to issue the corresponding decree of registration in favor of the petitioners. Attached to the application was the technical description of the Lot as Lot Psu-162620 signed by Robert C. Pangyarihan, Officer-in-Charge of the Survey Division, Bureau of Lands, which stated, "[t]his survey is inside IN-12 Mariquina Watershed." CA 141, as amended, remains to this day as the existing general law governing the classification and disposition of lands of the public domain other than timber and mineral lands.17. The following are the existing policies used as references in this index: The following are other existing policies related to CBFM and CS: The following are the policies related to CBFMA and CS that were repealed and/or amended: Frequently Asked Questions [link to document], Adopting Community-based Forest Management as the National Strategy to Ensure the Sustainable Development of the Countrys Forestlands Resources and Providing Mechanisms for Its Implementation, Declaring a Moratorium on the Cutting and Harvesting of Timber in the Natural and Residual Forests and Creating the Anti-Illegal Logging Task Force, Production Sharing Agreement with Peoples Organization in the Harvest of Forest Plantations Owned by the Government Inside CBFM Areas, Exemption of Community Based Forest Management Projects from the Payment of Administrative Fees, Guidelines on the Establishment and Management of the CBFM Special Account, Guidelines Governing the Issuance and Transfer of Certificate of Stewardship (CS) within CBFM Areas, Revised Rules and Regulations for the Implementation of Executive Order 263, otherwise known as the Community-Based Forest Management Strategy (CBFMS), DENR Manual of Authorities on Technical Matters, Promoting Tree Plantation Development and Liberalizing Harvesting and Transport of Planted Trees and Tree Derivatives for Inclusive Growth and Sustainable Development, Enhanced Guidelines and Procedures in the Preparation/Updating of the Community Resource Management Framework (CRMF) and Five-Year Work Plan (FYWP) for the CBFMA, Approval/Affirmation of Community Resource Management Framework (CRMF) and Five-Year Work Plan (FYWP) for the CBFMA, Guidelines for the Affirmation of Community Resource Management Framework (CRMF) and Approval of Five-Year Work Plan (FYWP) of the Holders of Community-Based Forest Management Agreement (CBFMA), Integration of all the Community-based Forest Management Strategy and People-Oriented Forestry Programs and Projects into the DENR Regular Structure), DAO 1998-41: Guidelines on the Establishment of Community-based Forest Management (CBFM) Projects within Watershed Reservations, Amending DAO 98 Series of 1998 to include CBFMP under the Coverage of Program D of the Comprehensive Agrarian Reform Program (CARP) and the National Anti-Poverty Program, Operationalization of the CBFM Program at the Regional, PENR and CENR Offices, Test Implementation of the Project Impact Monitoring and Evaluation System (PRIMES) as Monitoring and Evaluation Guidelines for Community-Based Forest Management Program (CBFMP), Rules and Regulations for the Implementation of Executive Order No. She has a right or interest to protect as she was the one dispossessed and thus, she can file the action for forcible entry. 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 The certificates of stewardship are actually contracts of lease granted by the DENR to actual occupants of parcels of land under its ISF programs for a period of twenty-five (25) years, renewable for another twenty-five (25) years.45 The DENR awarded contracts of stewardship to ISF participants in Barangay San Isidro (or Boso-boso) and the other barangays based on the Inventory of Forest Occupants the DENR had conducted.46. All agricultural, timber, and mineral lands of the public domain, waters, minerals, coal, petroleum, and other mineral oils, all forces of potential energy, and other natural resources of the Philippines belong to the State, and their disposition, exploitation, development, or utilization shall be limited to citizens of the Philippines, or to corporations or associations at least sixty per centum of the capital of which is owned by such citizens, subject to any existing right, grant, lease, or concession at the time of the inauguration of the Government established under this Constitution. Issuance of Permit, Licenses, ECC Lease Agreements and Other Similar Instruments by permitting agencies. What is a condominium? The GRANTEE has the right to nominate their heir to the Stewardship Agreement, subject to the approval of the Secretary or his authorized representative, to facilitate orderly transfer upon the death or incapacity of the original stewards, movement outside of the area by the stewards, and change of vocation of the Certificate of Stewardship holders. ( It was created not to hinder and delay but to facilitate and promote the administration of justice. Petitioners case falters even more because of the issuance of Proclamation No. ", 25 "Sec. 439-440. Viewed under this legal and factual backdrop, did petitioners acquire, as they vigorously argue, private rights over the parcel of land prior to the issuance of EO 33 segregating the same as a watershed reservation? 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). /ProcSet [ /PDF /ImageC ] Congress permanently Can I operate? 03-06145 on 25 June 1978. WebCertificate of Stewardship Contract (CSC) and duly signed by the issuing authority; and 5. In cases of water rights for irrigation, water supply, fisheries, or industrial uses other than the development of water power, beneficial use may be the measure and limit of the grant. 67. Petitioners further contend that town sites are considered alienable and disposable under CA 141. ", Lastly, the Solicitor General pointed out that attached to petitioner Edna T. Collados [as original applicant] application is the technical description39 of the Lot signed by Robert C. Pangyarihan, Officer-in-Charge of the Survey Division of the Bureau of Lands. The letter states: "That the land sought to be registered is situated at San Isidro (Boso-boso), Antipolo, Rizal, with an area of ONE HUNDRED TWENTY SIX POINT ZERO SEVEN SIXTY SIX (126.0766) hectares, more particularly described in Psu-162620, which is within the Marikina Watershed Reservation under Executive Order No. 33, which established the Marikina Watershed Reservation, certain parcel of land of the public domain embraced therein situated in Sitios Bosoboso, Veterans, Kilingan and Barangay San Joseph and Paenaan, Municipality of Antipolo, Province of Rizal and place the same under the Integrated Social Forestry Program of the Department of Environment and Natural Resources in accordance with existing laws, rules and regulations, which parcel of land is more particularly described as follows: "A PARCEL OF LAND, within the Marikina Watershed Reservation situated in the Municipality of Antipolo, Province of Rizal, beginning at point "1" on plan, being identical to corner 1 of Marikina Watershed Reservation; thence. Petitioners arguments find no basis in law. Im selling own business. The Bockasanjo ISF Awardees Association, Inc., an association of holders of certificates of stewardship issued by the DENR under its Integrated Social Forestry Program, filed with the Court of Appeals on November 29, 1991 a Motion for Leave to Intervene and to Admit Petition-In-Intervention. Operating without a license is subject to a $1,000 per day civil penalty and criminal penalties. $4%&'()*56789:CDEFGHIJSTUVWXYZcdefghijstuvwxyz " ? (Sgd.) << R). 107764 October 4, 2002. ( XIV, Sec. Time to intervene. A lock ( Finally, it is of no moment if the areas of the MWR are now fairly populated and vibrant communities as claimed by petitioners. 1637 reads: AMENDING PROCLAMATION NO. ( On the Casile side this would mean direct siltation of the Mangumit river which drains to the water impounding reservoir below. The 1935, 1973, 1987 Philippine Constitutions. The Court said: "It should be noted further that the doctrine of estoppel or laches does not apply when the Government sues as a sovereign or asserts governmental rights, nor does estoppel or laches validate an act that contravenes law or public policy, and that res judicata is to be disregarded if its application would involve the sacrifice of justice to technicality. After the passage of the 1935 Constitution, Commonwealth Act No. No. Containing an area of three thousand seven hundred eighty (3,780) Hectares, more or less. The Solicitor General maintained that the decision was null and void. 6657 has suspended the authority of the President to reclassify forest or mineral lands into agricultural lands. JFIF LEAD Technologies Inc. V1.01 All income/proceeds derived from the land shall accrue to the CS holder. } !1AQa"q2#BR$3br An applicant, like the private respondents herein, for registration of a parcel of land bears the burden of overcoming the presumption that the land sought to be registered forms part of the public domain (Director of Lands vs. Aquino, 192 SCRA 296). 8), and 1987 Constitution (Art. All content is in the public domain unless otherwise stated. The Court ruled: "We do not agree. (Sgd.) 1 A^(fh}QAQE QE RZ( ( ( ( ( ( ( ( ( ( 'QE QE QE QE QE QE QE QE QE QE QE QE QE QE QE QE QE QE QE QE QE QE QE QE QE QE QE QE QE QE QE QE QE QE QE P(((((((((((((((((((((R]cQE QE QE QE QE QE QE QE QE (!8( ((aEPEPEPEPEPEPIKE ( An imperfect title may have been derived from old Spanish grants such as a titulo real or royal grant, a concession especial or special grant, a composicion con el estado or adjustment title, or a titulo de compra or title through purchase.29 Or, that he has had continuous, open and notorious possession and occupation of agricultural lands of the public domain under a bona fide claim of ownership for at least thirty years preceding the filing of his application as provided by Section 48 (b) CA 141. ", The Court further held that "the right of reversion or reconveyance to the State of the public properties registered and which are not capable of private appropriation or private acquisition does not prescribe.". They claimed that they are the actual occupants of the Lot pursuant to the certificates of stewardship issued by the DENR under the ISF for tree planting purposes. 2. According to then DENR Secretary Victor Ramos, Proclamation No. Population growth and industrialization have taken a heavy toll on the environment. >>

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