Case Digest (G.R. No. L-2746)
Facts:
Mateo Carino v. The Insular Government, G.R. No. 2746, December 06, 1906, the Supreme Court En Banc, Willard, J., writing for the Court.On June 22, 1903, petitioner Mateo Carino, through his attorney-in-fact Metcalf A. Clarke, filed a petition in the Court of Land Registration asking to be inscribed as owner of a tract of agricultural land of about 14½ hectares in the municipality of Bagnio, Province of Benguet. The Government of the Philippine Islands and the Government of the United States appeared and opposed the petition; the United States asserted the land formed part of the military reservation of Baguio. The Court of Land Registration rendered judgment in favor of the petitioner.
Respondents appealed the Court of Land Registration's decision to the Court of First Instance of Benguet, under the law then in force, where the case was tried de novo. The Court of First Instance dismissed the petition. Carino brought the case to this Court by bill of exceptions.
At trial the petitioner produced no documentary title to the land except a possessory information obtained in 1901 (under the Mortgage Law, art. 394), which the Court below found to carry only the evidentiary weight of mere possession. The lower court further found that petitioner had not shown title from the Government, that the land had been used primarily for pasturage and not continuously inhabited, and that petitioner in 1894 had sought to obtain title under existing laws and in 1901 contracted to sell the land to Clarke for P6,000 "when he obtained title," describing himself only as in possession. The court also found the land’s present value to be upwards of P50,000.
The petitioner argued that long, immemorial occupation gave rise to a conclusive presumption of grant (prescription/presumptive grant), invoking U.S. authorities such as United States v. Chaves and Hays v. United States. The Court reviewed Spanish colonial legislation (Law 14, the Royal Cedula of 1754, the 1880 regulations, and the Royal Decree of February 13, 1894) and this Court...(Pro-only)
Issues:
- Can mere possession of public agricultural land confer title against the Government (i.e., does prescription run against the State)?
- Does a presumption of grant from immemorial possession apply in the Philippines so as to vest title in the possessor?
- Is paragraph 6 of section 54 of Act No. 926 (the Public Land Act) applicable to la...(Pro-only)
Ruling:
- (Pro-only)
Ratio:
- (Pro-only)
Doctrine:
- (Pro-only)