Case Digest (G.R. No. 129103) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
On February 23, 1904, Mateo Carino filed Petition No. 561 in the Court of Land Registration, seeking title to a 40-hectare, 1-are, 13-centare tract in Baguio, Benguet, including a wooden house roofed with rimo. He described boundaries abutting the lands of Sepa Carino, H. Phelps Whitmarsh, Calsi, Kuidno, Esteban Gonzales, the Civil Government, Talaca, Sisco Carino, and Mayengmeng. The Insular Government contested on the ground that the property was public land with no egresion title. The court consolidated Carino’s petition with Petition No. 834 by Antonio Rebollo and Vicente Valpiedad, who claimed a portion of the same tract. After documentary and oral evidence, the Land Registration Court found that Carino’s predecessor possessed a different tract in 1884, sold it in 1893, and only in 1897–1898 occupied the present land. His possessory information of March 7, 1901, registered March 11, 1901, covered just 28 hectares, used for pasture and sowing. The court concluded there was n Case Digest (G.R. No. 129103) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Petition and Subject Matter
- On February 23, 1904, Mateo Carino filed Petition No. 561 in the Court of Land Registration seeking registration of ownership to a parcel of land in Baguio, Benguet, described as follows:
- Area: 40 hectares, 1 are, and 13 centiares
- Improvements: Wooden house roofed with rimo
- Boundaries:
- North – 1,048 m 20 dm abutting lands of Sepa Carino, H. P. Whitmarsh, and Calsi
- East – 991 m 50 dm abutting lands of Kuidno, Esteban Gonzales, and the Civil Government
- South – 115 m 60 dm abutting lands of Talaca
- West – 982 m 20 dm abutting lands of Sisco Carino and Mayengmeng
- The Insular Government opposed, contending the entire tract was public land never alienated by the State.
- Consolidation and Trial
- Petition No. 561 was consolidated with Petition No. 834 (Antonio Rebollo and Vicente Valpiedad) due to overlapping claims on a portion of the same land.
- Trial proceeded on documentary and oral evidence, including:
- Possessory information filed March 7, 1901 (registered March 11, 1901), describing only 28 hectares along the country road to barrio Pias
- Carino’s testimony and that of Government witnesses regarding his occupancy history
- Possession History
- 1884–1893: Carino erected a domicile on land north of the present claim (Donaldson Sim’s property), sold it to Cristobal Ramos, who later sold it to Sim
- 1893–1897: Carino resided on adjacent Whitmarsh property (formerly occupied by his wife’s ancestors Ortega and Minse)
- Circa 1897–1898: Carino relocated to and built a house on the land now claimed, occupying “some portion” since then
- Trial Court Decision
- Found Carino’s predecessors and Carino himself never possessed exclusively and adversely the entire 40 ha prior to construction of the house
- Determined the only valid documentary claim was to 28 ha as per the possessory information, which did not qualify under Spanish law for free patent
- Dismissed both petitions and adjudged the property as public land
Issues:
- Whether Carino established private ownership of the claimed parcel under Spanish or American law
- Whether the possessory information of March 1901 conferred title by composición or prescription
- Whether Act No. 627 and Act No. 648 allow registration of lands exceeding 16 hectares by ten-year prescription
- Whether the land remained public as classified by the Government and subject solely to its disposition
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)