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Baguio City Et Al V Marcos Et Al
Baguio City Et Al V Marcos Et Al
Baguio City Et Al V Marcos Et Al
Marcos, et al
(Petitioners vs. respondents)
G.R. No. L-26100
February 28, 1969
J. Sanchez
FACTS:
Petitioners attack the jurisdiction of the Court of First Instance of Baguio to
reopen cadastral proceedings under Republic Act 931.
April 12, 1912: The Director of Lands in the Court of First Instance of
Baguio instituted to reopen the cadastral proceedings (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.
July 25, 1961: Respondent Belong Lutes petitioned the cadastral court to
reopen said Civil Reservation Case No. 1 as to the parcel of land he
claims. On the grounds that,
1. He and his predecessors have been continuous possession and
cultivation of the land since Spanish times, or before July 26, 1894, paying
the taxes thereon; and
2. His predecessors were illiterate Igorots, thuswere not able to file
their claim to the land in question.
March 9, 1962 in Yaranon vs. Castrillo [Civil Case 946, Court of First
Instance of Baguio] which declared that such tree farm leases were null
and void.
September 14, 1962: the cadastral court reversed its own ruling of May 8,
1962, allowed petitioners to cross- examine the witnesses of respondent
Lutes.
November 13, 1964: All the petitioners went to the Court of Appeals on
certiorari, prohibition, and mandamus with preliminary injunction. They
questioned the cadastral court's jurisdiction over the petition to reopen and
the latter's order of August 5, 1963 dismissing private petitioners'
opposition.
The court held that petitioners were not bound by the declaratory judgment
heretofore hated. Nevertheless, the appellate court ruled that as lessees,
private petitioners had no right to oppose the reopening of the cadastral
case.
ISSUES:
1. Whether or not the title of RA 931 is in conflict with Section 1 of the
same act
2. Whether or not private petitioners have personality to appear in the
reopening proceedings
3. Whether or not the reopening petition was filed outside the 40-year
period preceding the approval of Republic act 931
RULING:
1. Yes. The 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.
through the Solicitor General, and if after hearing the parties, said court
shall find that all conditions herein established have been complied wth,
and that all taxes, interests and penalties thereof have been paid from the
time when land tax should have been collected until the day when the
motion is presented, it shall order said judicial proceedings reopened as if
no action has been taken on such parcels.
2. Yes. The court allowed the reopening of the case since the case was
filed within the 40-year period imposed by the act.
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 wordings of the title are to followed, the date April 12, 1912, which
is the date of the Director of Lands instituting the reopening of the case,
would render the petition invalid since it is already outside the 40-year
period.
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. Thus act is a pice 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 incosistency between the title and its section.
The title of the act is indisputable 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 to reopen the case, decision on which
was rendered on Noember 13, 1922, comes wthin the 40-year period.