CITY OF BAGUIO V.

MARCOS
G.R. No. L-26100, February 28, 1969

I. FACTS
 1912: The cadastral proceedings sought to be reopened regarding the Baguio Townsite were
instituted by the Director of Lands in the Court of First Instance Baguio
 1922: The land was amongst those declared public lands
 1961: Belong Lutes petitioned the cadastral court to reopen the case
 RESPONDENT’S CASE
o He and his predecessors have been in actual, open, adverse, peaceful, and continuous
possession and cultivation of the land since Spanish times while paying the taxes
o His predecessors were illiterate Igorots without personal notice of the cadastral
proceedings
 PRIVATE PETITIONER’S CASE
o They are tree farm lessees upon agreements executed by the Bureau of Forestry
o Declaratory relief judgment does not bind them as they were not parties to that action
 Court of First Instance denied the petitioners’ right to intervene in the case as a final
declaratory relief judgment rendered tree farm leases null and void
 Cadastral Court reversed its ruling and allowed petitioners to cross-examine Lutes’s witnesses
 Cadastral Court dismissed private petitioners’ opposition to the reopening\
 City of Baguio lodged a motion to dismiss the petition to reopen
 CITY OF BAGUIO’S CASE
o Declaratory relief judgment was not binding on the parties not thereto
o Reopening petition should have been published in accordance with the Cadastral Act
 Cadastral court denied the petition for lack of merit
 Petitioners went to CA to question the jurisdiction of the cadastral court over the petition to
reopen
 CA RULING
o Petitioners were not bound by the declaratory judgment
o However, as lessees, private petitioners had no right to oppose the reopening of the
cadastral case

II. ISSUES
 Whether or not private petitioners have personality to appear in the reopening proceedings?
 Whether or not the cadastral court have power to reopen the cadastral proceedings?

III. RULING
IV. RATIO
 RA 931: Allows a petition for reopening on lands about to be declared or already declared
land of the public domain by virtue of judicial proceedings. This is only applicable to lands
that have not been alienated, reserved, leased, granted, or provisionally or permanently
despised of by the Government
o If the land subject of a petition to reopen has already been leased by the government,
that petition can no longer prosper
 Since the cadastral court has already acquired jurisdiction over the parcel of land, the petition,
therefore, need not be published
 Ratio Legis: the spirit or intention of a statute prevails over the letter thereof
 Title of the Law: AN ACT TO AUTHORIZED THE FILING IN THE PROPER COURT,
UNDER CERTAIN CONDITIONS, OF CERTAIN CLAIMS OF TITLE TO PARCELS OF
LAND THAT HAD BEEN DECLARED A PUBLIC LAND, BY VIRTUE OF JUDICIAL
DECISIONS RENDERED WITHIN THE 40 YEARS NEXT PRECEDING THE
APPROVAL OF THIS ACT
o The Court leaned towards a liberal view. Thus, the law provides remedial relief to
landowners, who, before the Act, had no legal means of perfecting their titles