Case Digest (G.R. No. 12790)
Facts:
Aniceto Lacson v. The Government of the Philippine Islands, G.R. No. 12790, February 17, 1919, the Supreme Court En Banc, Torres, J., writing for the Court.Petitioner Aniceto Lacson sought inscription in the Registry of Property of the entire Island of Sicogon (municipality of Balasan, Iloilo) as owner, alleging acquisition by purchase from predecessors and uninterrupted, peaceful, adverse possession under title of owner. The Government of the Philippine Islands (through the Director of Lands and Director of Forestry), the municipality of Balasan, and several island residents opposed the application. The municipality and several residents later withdrew their oppositions after agreements with Lacson; the municipality’s withdrawal was conditioned on reservation of certain public lots.
At the trial level (judge of the sixteenth judicial district), the petition for inscription was denied by judgment dated October 12, 1916. Lacson moved for a new trial; the motion was overruled, he excepted, and his bill of exceptions was certified and forwarded to the Supreme Court. Counsel for Lacson then appealed to the Supreme Court by bringing the bill of exceptions and the appeal.
At trial, Lacson offered testimony and Exhibit B—a sale document by Ramon Fontanet to Lacson—asserting a chain of title: a composition (royal) concession of Sicogon to Ynchausti & Co. during the Spanish regime; a sale by Ynchausti & Co. to Ramon Fontanet; and Fontanet’s transfer to Lacson in payment of a debt. Lacson and witnesses testified that the island had been possessed by Ynchausti & Co. (through agents) for decades, then by Fontanet, and thereafter by Lacson; that possession was open, exclusive, peaceful and adverse; and that the archives and many private papers (including any royal concession and Fontanet’s records) were destroyed when insurgents burned records and Fontanet’s house in 1898. Opponents produced two witnesses whose testimony did not rebut the core evidence of longstanding possession; the Bureau of Forestry had once authorized timber cutting permits, but those were protested and suspended after Lacson’s representative intervened.
The primary factual questions presented were (1) whether the Spanish government had in fact granted a composition title to Ynchausti & Co. entitling that firm to Sicogon, and (2) if documentary proo...(Subscriber-Only)
Issues:
- Was there proof that the Island of Sicogon had been ceded by the Spanish government to Ynchausti & Co. so that Ynchausti & Co. could be treated as absolute owner?
- If such a concession could not be conclusively proven by documentary title, did the possession of Ynchausti & Co., Ramon Fontanet, and Aniceto Lacson satisfy the requirements (open, exclusive, adverse, under title of owner for the period required) for inscription under ...(Subscriber-Only)
Ruling:
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Ratio:
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Doctrine:
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