Case Digest (G.R. No. L-2746) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In Mateo Carino v. The Insular Government (7 Phil. 132, G.R. No. 2746, December 6, 1906), the petitioner, Mateo Carino, by his attorney-in-fact Metcalf A. Clarke, filed on June 22, 1903 before the Court of Land Registration a petition to be inscribed as owner of a 14-hectare tract of agricultural land in Baguio, Province of Benguet. The Government of the Philippine Islands and the United States Government opposed, asserting the property formed part of the military reservation of Baguio. The Court of Land Registration ruled for Carino, whereupon both governments appealed to the Court of First Instance of Benguet for a de novo trial, which dismissed the petition. Carino offered as title evidence only a possessory information secured in 1901 under Article 394 of the Mortgage Law, showing mere possession. He also relied on an 1894 attempt to secure title under Spanish laws and a 1901 sales contract with Clarke. The provincial court found the land worth over ₱50,000 but held that, ab Case Digest (G.R. No. L-2746) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Parties and Subject Matter
- Petitioner/Applicant: Mateo Carino, represented by attorney-in-fact Metcalf A. Clarke.
- Respondents/Opponents: The Insular Government of the Philippine Islands and the United States Government.
- Property: A tract of agricultural land in the Municipality of Bagnio, Province of Benguet, containing 14½ hectares.
- Petition and Opposition
- June 22, 1903 – Petition filed in Court of Land Registration to inscribe Carino as the owner.
- Government of Philippine Islands and U.S. Government appeared to oppose, claiming the land was part of the Baguio military reservation.
- Procedural History
- Court of Land Registration: Judgment in favor of Carino.
- Appeal de novo to Court of First Instance, Province of Benguet: Petition dismissed.
- Appeal to the Supreme Court via bill of exceptions by petitioner.
- Evidence and Contractual Arrangements
- Documentary Evidence: Possessory information (1901) under Mortgage Law (Art. 394), conferring only effects of mere possession.
- Contract (1901) between Carino and Clarke: agreement to sell for ₱6,000 upon obtaining title; Carino described himself merely as in possession.
- Land Use: Primarily pasturage, no permanent habitation for many years, insignificant cultivation, no post-insurrection use by petitioner.
Issues:
- Title by Possession
- Whether mere possession of agricultural land against the Government gives title by prescription or presumption of grant.
- Whether a possessory information under the Mortgage Law suffices to establish ownership.
- Presumption of Grant
- Whether immemorial use and occupation of land by an aboriginal occupant (Igorot) creates a conclusive presumption of a grant from the Spanish Crown.
- Compatibility of such presumption with statutory rule that limitations do not run against the State.
- Applicability of Public Land Act
- Whether paragraph 6, Section 54 of Act No. 926 (Public Land Act) applies to public agricultural lands in Benguet.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)