G.R. No. 40177 - Li Seng Giap and Co. vs. Director of Lands

Li Seng Giap & Co., a partnership composed of aliens (individuals not citizens of the Philippine Islands or the United States), filed an application for the registration of three parcels of land.
The application was filed before the Court of First Instance of Camarines Sur under the provisions of Act No. 496 and Chapter VIII of Title II of Act No. 2874.
The Director of Lands opposed the application on the grounds that the lands were public lands under the control of the Government of the Philippine Islands and that an alien could not invoke the benefits of section 45 of the Act No. 2874.
The opposition did not invoke Act No. 496, as that law merely set forth procedural requirements concerning issuance or denial of titles.

The three parcels in dispute are agricultural lands cultivated with coconut, abaca, and cacao, with coconut trees ranging in age from one to forty years.
Historical occupation dates back to the Spanish regime, with natives (Salon, Ceron, Labordes, Quitales, Vargas) holding the land under a claim of ownership despite an indeterminate starting date.
The occupation continued uninterrupted for over fifty-five years until the land was sold to Sebastian Palanca, who, like the applicant, is an alien.
Palanca possessed the land without securing any form of gratuitous title or possessory information under the Royal Decree of February 13, 1894 (incorporating relevant provisions of the Maura Law), which provided a window for obtaining title by cultivation and possession.
By rule in Article 80 of the regulations of the Royal Decree, the period within which possessors could perfect their claim lapsed on April 17, 1895, causing the land to revert to state ownership as part of the public domain.

The applicant bases its claim on section 54, paragraph 6 of Act No. 926, contending that through open, continuous, exclusive, and notorious possession for more than ten years prior to July 26, 1904, it has acquired a right to have the certificate of title issued in its name.
The applicant cites precedents such as Tan Yungquip vs. Director of Lands and Central Capiz vs. Ramirez to support the view that possession under a bona fide claim of ownership may give rise to a presumption of a government grant.
The crux of the applicant’s argument is that the provisions of Act No. 926 and related statutes do not distinguish between aliens and citizens when possession is proven.

The decision discusses the application of the Maura Law and the Royal Decree of February 13, 1894, which allowed for the perfecting of title via possessory proceedings by cultivators if certain conditions were met.
Article 80 of the decree specifies a fixed period for such actions, after which the right to free title lapses, with the property reverting to the state.
The case highlights that the land in question had reverted to public domain due to the failure by the former possessors and Palanca to secure title within the prescribed period.
Further, the statutory scheme under Act No. 926, particularly section 54, is analyzed in light of the Organic Law of the Philippine Islands (Act of Congress of July 1, 1902), which restricts the issuance of titles on public lands to citizens or those with appropriate domestic affiliation.

Whether an alien partnership such as Li Seng Giap & Co. can be entitled to registration of title under the provisions of section 54, paragraph 6 of Act No. 926 and section 45, paragraph (b) of Act No. 2874.
Whether the term “all persons” in the statutory provisions should be interpreted to include aliens, or if it is limited to citizens of the Philippine Islands or the United States (or their insular possessions).

Whether the three parcels of land, despite being cultivated and possessed for decades, are to be considered parts of the public domain or are of private character due to long-standing occupation.
Whether historical possession under the Spanish regime, followed by sale and continued possession by an alien, can convert public domain lands into private property through prescription.

Whether the rulings in Tan Yungquip vs. Director of Lands, Central Capiz vs. Ramirez, and Agari vs. Government of the Philippine Islands are controlling in determining that possession by an alien may give rise to a presumption of a government grant.
Whether such precedents are applicable when considering that these earlier cases involved lands which were already of private ownership or had a different legal history compared to lands reverted to state control by the Maura Law.