Facts:

The case involves the Heirs of Datu Pendatun, represented by their guardian Edward M. Kuder, as the applicants and appellees, against the Director of Lands, who is the appellant. The events leading to this case began on December 12, 1929, when the heirs filed an application for the registration of a tract of land measuring 3,071 hectares located in the district of Buluan, Province of Cotabato. This application was made under the provisions of the Land Registration Act (No. 496) or the Public Land Act (No. 2874). However, the application faced opposition from approximately ninety private claimants, as well as from the Director of Lands and the Director of Forestry, who contended that the land in question was part of the public domain.

On November 18, 1930, a compromise was reached between the private claimants and the applicants, wherein the applicants agreed to exclude a 500-hectare eastern portion of the land from their application, and in return, the private oppositors w...

Facts:

Background of the Case

The case involves an appeal by the Director of Lands against a decision of the Court of First Instance of Cotabato, which awarded a 3,071-hectare tract of land in Buluan, Cotabato, to the Heirs of Datu Pendatun. The heirs, represented by their guardian Edward M. Kuder, filed an application for land registration under the Land Registration Act (No. 496) or the Public Land Act (No. 2874) on December 12, 1929.

Oppositions and Compromise

Ninety private claimants opposed the application, asserting ownership over portions of the land. The Director of Lands and the Director of Forestry also opposed, claiming the land was public domain. On November 18, 1930, a compromise was reached: the heirs excluded a 500-hectare eastern portion and a 500-hectare western portion from their application, and the private oppositors withdrew their claims to the remaining land.

Trial Court Decision

On June 15, 1931, the trial court ruled in favor of the heirs, ordering the registration of the land except for the excluded portions. The court found that the heirs and their ancestors had possessed the land "since time immemorial" in a peaceful, public, continuous, and exclusive manner, cultivating portions and using it for grazing and planting crops.

Director of Lands' Appeal

The Director of Lands appealed, assigning two errors: (1) the trial court erred in ordering registration in favor of the applicants instead of declaring the land public domain, and (2) the trial court erred in denying the motion for a new trial.

Issue:

• (Unlock)

Ruling:

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Ratio:

1. Insufficient Proof of Possession: The applicants failed to provide sufficient evidence to establish that they or their ancestors had possessed the land in an open, continuous, exclusive, and notorious manner, as required by law. The genealogical evidence presented only proved political succession, not private ownership or possession.

2. Lack of Bona Fide Claim of Ownership: There was no evidence that the applicants or their ancestors ever made a bona fide claim of ownership or held the land adversely and exclusively against all others. The land remained largely uncultivated and undeclared for taxation until 1929.

3. Public Domain Presumption: In the absence of evidence showing acquisition of the land through composition title, possessory information title, or any other legal means, the land must be presumed to be part of the public domain.

4. Reversal of Trial Court Decision: The Supreme Court found that the trial court's decision was based on insufficient and incomplete findings of fact. The land was declared public domain, and the registration application was denied.

Conclusion:

The Supreme Court ruled that the Heirs of Datu Pendatun failed to meet the legal requirements for land registration under the Public Land Act. The land was declared public domain, and the trial court's decision was reversed. Costs were imposed de oficio.