Land struggle among the Ibaloys: Landmark case of Cariño vs.

Insular Government
The Mateo Cariño case is a pivotal moment in Philippine history, addressing land rights and
the recognition of indigenous ancestral domains. It highlights the ongoing struggles of indigenous
communities, like the Ibaloy in Baguio City and elsewhere, facing threats from development,
mining, and land encroachments by outsiders. This case's legacy is a vital legal basis for indigenous
peoples' ongoing battle for land rights and selfdetermination, emphasizing the need to protect the
ancestral domains and cultural heritage of Philippine indigenous communities.
Mateo Carino, an Ibaloy chieftain who belonged to the baknang (wealthy) class, owned a vast
amount of land in Kafagway, the original name of Baguio. He was a respected leader and warrior
who had successfully led a revolt against the Spaniards in La Trinidad. However, Carino's
conversion to Christianity during the Spanish period played a significant role in the granting of land
titles to his holdings.
In 1901, Carino became a representative of Baguio in the US Insular government.
However, in a historical twist, he was later accused of aiding and providing refuge to
President Aguinaldo as he fled to Hong Kong. This allegation led to the confiscation of Carino's
lands by the Americans, which marked the beginning of a legal battle over the rights of indigenous
peoples to their ancestral lands and domains.
On the 23d of February, 1904, filed his petition in the Court of Land Registration praying
that there be granted to him title to a parcel of land consisting of 40 hectares, 1 are, and 13
centares, and situated in the town of Baguio, Province of Benguet, together with a house erected
thereon and constructed of wood and roofed with rimo.
At the heart of the Mateo Cariño case is the question of who owns the land. The case arose
from a dispute over a piece of land in what is now known as Baguio City, which was then part of the
Philippine Islands under American colonial rule. Mateo Cariño, a member of the Ibaloy tribe,
claimed ownership of the land, while the Philippine Commission, the legislative body of the Insular
Government, asserted that the land was public land and therefore owned by the government.
The Insular Government opposed the granting of these petitions, alleging that the whole
parcel of land is public property of the Government and that the same was never acquired in any
manner or through any title of egresion from the State.
In 1907, Carino challenged the US Colonial Government's decision to seize his pasture lands
for use as a military base. He filed a petition in the Court of Land Registration requesting title to the
land, which consisted of 40 hectares, 1 are, and 13 centares, and included a wooden house with a
rimo roof. However, the Insular Government opposed his petition, claiming that the entire parcel of
land was public property and had never been acquired in any way or through any title of egresion
from the state.
After trial, and the hearing of documentary and oral proof, the court of Land Registration
rendered its judgment in these terms:
Therefore the court finds that Cariño and his predecessors have not possessed
exclusively and adversely any part of the said property prior to the date on which
Cariño constructed the house now there — that is to say, for the years 1897 and
1898, and Cariño held possession for some years afterwards of but a part of the
property to which he claims title. Both petitions are dismissed and the property in
question is adjudged to be public land. (Bill of exceptions, p. 15.)
By reason of the findings set forth it is clearly seen that the court below did not err:
1) In finding that Mateo Cariño and those from whom he claims his right had not
possessed and claimed as owners the lands in question since time immemorial;
2) In finding that the land in question did not belong to the petitioner, but that, on the
contrary, it was the property of the Government.

However, Mateo Carino did not live long to witness the reversal of the aforesaid decision in
1909. In its historic decision, the US Supreme laid the following:
▪ The writ of error is the usual way to bring cases to this Court, while appeals are
mainly used for equity cases and for cases where the Supreme Court of the Philippine
Islands affirms a dismissal of a land registration application by the Court of Land
Registration.
▪ Although a province may be excepted from the operation of Act No. 926 of 1903 of the
Philippine Commission which provides for the registration and perfecting of new titles,
one who actually owns property in such province is entitled to registration under Act
No. 496 of 1902, which applies to the whole archipelago.
▪ While, in legal theory, sovereignty is absolute against foreign nations. However, in
practice, it depends on strength and varies. A new sovereign must decide how much to
uphold theoretical ties to the previous sovereign versus acknowledging real
circumstances.
 ▪ The Philippines' acquisition didn't aim to take the residents' occupied lands. As per
the July 1, 1902 Organic Act (c. 1369, 32 Stat. 691), property rights were to benefit
inhabitants. Longtime landowners couldn't lose their land due to non-compliance with
Philippine Commission or Spanish law ceremonies.
▪ The Organic Act of the Philippines made a bill of rights embodying safeguards of the
Constitution, and, like the Constitution, extends those safeguards to all.
▪ 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.
▪ Title by prescription against the crown existed under Spanish law in force in the
Philippine Islands prior to their acquisition by the United States, and one occupying
land in the Province of Benguet for more than fifty years before the Treaty of Paris is
entitled to the continued possession thereof.
The ruling acknowledged indigenous rights to ancestral lands, setting a legal precedent for
recognizing Philippine customary law rooted in local culture. It emphasized customary law's
importance in legal matters and indigenous self-determination. Despite benefiting the Ibaloys, the
ruling remained unimplemented. Camp John Hay retained land ownership through Native Title,
with no restitution or compensation.