CARIO vs INSULAR GOVERNMENT The Court ruled in the affirmative.
212 US 449 February 23, 1909 Cario, who has occupied the subject land for more
FACTS:
Plaintiff Mateo Cario is an Igorot of the Province of
Benguet, where the subject land lies. For more than
fifty years before the Treaty of Paris, April 11, 1899,
the plaintiff and his ancestors had held the land as
owners. They all had been recognized as owners by
the Igorots, and he had inherited or received the land
from his father in accordance with Igorot custom. No
document of title, however, had issued from the
Spanish Crown, and although, in 1893-1894 and again
in 1896-1897, he made application for one under the
royal decrees then in force, nothing seems to have
come of it, unless, perhaps, information that lands in
Benguet could not be conceded until those to be
occupied for a sanatorium, etc., had been designated
a purpose that has been carried out by the
Philippine government and the United States. In 1901,
the plaintiff filed a petition for the granting of a
certificate of title over the subject land. Ultimately, the
Philippine Supreme Court ruled against Cario,
prompting him to file an appeal to the U.S. Supreme
Court.
ISSUE:
Whether or not Cario owns the subject property.
HELD:
than fifty years before the Treaty of Paris, cannot be
deprived of his land simply because he failed to
comply with the formalities required by the Spanish
law. Every presumption of ownership is in favor of one
actually occupying land for many years, and against
the government which seeks to deprive him of it, for
failure to comply with provisions of a subsequently
enacted registration act.
It is also worth noting that even the Solicitor General
admitted that the Igorots were hardly ruled by the
Spanish government. That being, it is unlikely that the
Spanish government would grant land titles to the
Igorots even if they will register their land under the
old Spanish Law. The US Supreme Court also ruled that
to follow the stand of the Solicitor General is to deprive
the land titles of the native, not only Igorots but all
native inhabitants of the Philippines.
The Constitution provides: no law shall be enacted in
said islands which shall deprive any person of life,
liberty, or property without due process of law, or deny
to any person therein the equal protection of the
laws. The term any person includes the natives (in
this case, the Igorots). All lands held under private
ownership during the Spanish era shall therefore be
presumed to be such. Failure to register under Spanish
Law did not revert said lands to the public domain.