G.R. No. 36699 - Heirs of Datu Pendatun vs. Director of Lands

The heirs of Datu Pendatun, represented by their guardian Edward M. Kuder, applied for the registration of a tract of land measuring approximately 3,071 hectares located in the district of Buluan, Province of Cotabato.
The applicants included minors (Salipada, Tinomimbang, Abu-Bakal, and Bagutao) whose title to the land was supported by claims of inheritance passed down from Datu Pendatun through a genealogical line originating with prominent local rulers such as Sultan Diluyudin.

Approximately ninety private claimants opposed the registration by claiming portions of the land, asserting that it was part of the public domain.
On November 18, 1930, a compromise was reached whereby:

The applicants agreed to exclude from their application a 500-hectare eastern portion (demarcated from corner 6 to corner 43 on Exhibit A).
The private oppositors withdrew their opposition regarding the remaining portion of the land, with the compromise also noting a “temporary” exclusion of a 500-hectare tract on the west side (between points 22 to 34 as shown on Exhibit A).

The Court of First Instance of Cotabato, on June 15, 1931, entered a judgment ordering the registration in favor of the applicants for the entire tract of land, except for the portions excluded under the compromise.
The decision, although brief, contained findings stating that:

The applicants inherited the land through a valid lineage dating back to Sultan Diluyudin and his successors.
The applicants and their predecessors, through inquilinos, had exercised possession by cultivating substantial areas, using parts of it for grazing, planting fruit trees, and engaging in the farming of palay, maize, and other crops.
Evidence of possession was drawn from the testimonies of several witnesses, with partial corroboration by the opposition’s witnesses, although no detailed account of continuous and exclusive possession was provided.

The trial court erred in ordering registration in favor of the applicants without declaring the land as public domain, despite the requirements set forth under the Public Land Act (Act No. 2874) and the Land Registration Act (No. 496).
The trial court erred in denying the motion for a new trial.

The record ultimately revealed that the applicants failed to prove, with the necessary degree of certainty, that they had continuously and exclusively possessed the land in a manner that satisfied statutory requisites.

Did the applicants prove, in accordance with paragraph (b) of section 45 of Act No. 2874, the open, continuous, exclusive, and notorious possession of the land under a bona fide claim of ownership?

Is the mere lineage from Sultan Diluyudin sufficient to establish rights over land that is part of the public domain, in the absence of concrete possession evidence?

Did the trial court err in registering the applicants’ claim on the land, given that the necessary evidence of actual possession and adverse claim was not demonstrated?

How did the compromise, which involved excluding specific portions of the land, impact the overall legitimacy of the applicants’ claim regarding continuous possession?