City of Baguio, ET AL. vs. PIO R. MARCOS, ET AL. G.R. No. L-26100 February 28, 1969 Sanchez, J.

FACTS:
On April 12, 1912, the Director of Lands in the Court of First Instance of Baguio instituted the reopening
of cadastral proceedings (a land registration/ titling proceeding) Civil Case No.1. A decision on
November 13, 1922 was rendered; the land involved (Baguio Townsite) was among those declared
public lands. On July 25, 1961, Belong Lutes petitioned cadastral court to reopen said civil case. He
claims that the land (Baguio Townsite) be registered in his name upon the grounds that 1.) he and his
predecessors have been in continuous possession and cultivation of the land since Spanish times 2.) his
predecessors were illiterate Igorots, thus were not able to file their claim to the land in question. On the
other hand, Francisco G. Joaquin Sr., Francisco G. Joaquin, Jr. and Teresita J. Buchholz, as tree farm
lessees of the land in question, opposed the reopening. Their contentions are as follows: 1.) The
reopening petition was filed outside the 40-year period provided by R.A. 931 2.) Petition to reopen the
case was not published 3.) as lessees of the land, they have a standing to appear in the reopening
proceedings. ISSUE/S: Statcon issue here is whether the reopening petition was filed outside the 40-year
period provided by R.A. 931 (enacted June 20, 1953). Joaquin’s group contests that the title of the said
act is in conflict with section 1 of the same act, thus invalidating the petition of Lutes to reopen the civil
case. Title of the act reads: AN ACT TO AUTHORIZE THE FILING IN THE PROPER COURT, UNDER CERTAIN
CONDITIONS, OF CERTAIN CLAIMS OF TITLE TO PARCELS OF LAND THAT HAVE BEEN DECLARED PUBLIC
LAND, BY VIRTUE OF JUDICIAL DECISIONS RENDERED WITHIN THE FORTY YEARS NEXT PRECEDING THE
APPROVAL OF THIS ACT. Section 1 of the act provides: SECTION 1. …in case such parcels of land, on
account of their failure to file such claims, have been, or are about to be declared land of the public
domain by virtue of judicial proceedings instituted within the forty years next preceding the approval of
this Act, are hereby granted… HELD: The court allowed the reopening of the case since the case was filed
within the 40-year period imposed by the act. Joaquin’s group believes that the difference between the
title (BY VIRTUE OF JUDICIAL DECISIONS RENDERED and in section 1 (by virtue of judicial proceedings
instituted), is material. If the title is to be followed, the date November 13, 1922 should be the date
used in reckoning the period (which is still within the 40-year period; counted from the date of the
enactment of R.A. 931 which is June 20, 1953). But if the wordings of the title are to be followed, the
date April 12, 1912, which is the date the Director of lands instituted the reopening of the case, would
render the petition invalid since it is already outside the 40-year period. The rule on statutory
construction provides that laws should be construed liberally (see page 12 of statcon book). The spirit or
the intent of the law should be looked upon and should prevail over its letter. In this case, R.A. 931
clearly gives an opportunity to any person who has any interest in any parcel of land which has been
declared as public land to present his claim within the time prescribed. This act is a piece of remedial
legislation; its intent provides a mode of relief to landowners who, before the act had no legal means of
perfecting titles. Therefore, the court cannot see an inconsistency between the title and its section. The
title of the act is indisputably clear, as it expresses the very substance of the law itself. The constitutional
jurisdiction that the subject of the statute must be expressed in the title, breathes the spirit of command
because the constitution does not exact of Congress the obligation to read during its deliberations the
entire text of the bill. Therefore, by the statute, the petition of Lutes to reopen the case, decision on
which was rendered on Nov. 13, 1922, comes within the 40-year period.