Title
Republic vs. Fangonil
Case
G.R. No. 57112-21
Decision Date
Nov 29, 1984
Applications for lot registration in a reservation were dismissed due to insufficient notice to predecessors and over fifty years of delay.
Font Size

Case Digest (G.R. No. 57112-21)

Facts:

  • The Republic of the Philippines, represented by the Director of Lands, is the petitioner.
  • Respondents include Judge Sinforoso Fangonil and several individuals: Modesta Paris, Lagya Paris, Samuel Baliwan, Pablo Ramos, Jr., Josephine Abanag, Menita T. Victor, Emiliano Bautista, and Odi Dianson.
  • The case originated from a 1912 petition regarding the Baguio Townsite Reservation, recorded as Expediente de Reserva No. 1, GLRO Reservation Record No. 211.
  • After the Land Registration Court was abolished in 1914, the case was transferred to the Court of First Instance (CFI) of Benguet.
  • The case aimed to determine which portions of the Baguio Townsite Reservation were private and eligible for registration under Act No. 496, as per Section 62 of Act No. 926.
  • A notice was issued on July 22, 1915, requiring claims for lots within the reservation to be filed within six months.
  • On June 13, 1922, the General Land Registration Office reported on registration applications, leading to a ruling by Judge C. M. Villareal on November 13, 1922.
  • The ruling declared all lands within the Baguio Townsite Reservation as public lands, with exceptions for public use and adjudicated private property.
  • Claims for private lands not registered within the specified period were permanently barred.
  • From 1972 to 1976, respondents filed applications for registration, claiming rights under Section 48(b) and (c) of the Public Land Law due to long possession.
  • The Director of Lands opposed these applications, citing lack of jurisdiction, prescription, and res judicata, and filed motions to dismiss.
  • The trial judge refused to dismiss the applications, prompting the Solicitor General to seek certiorari.

Issue:

  • (Unlock)

Ruling:

  • The Supreme Court reversed and set aside the trial court's order denying the motions to dismiss.
  • The application...(Unlock)

Ratio:

  • The Supreme Court found that the trial court erred in requiring evidence regarding the notice under Act No. 627, as records from Case No. 211 were destroyed during the war.
  • The burden of proof was on the applicants to show that their predecessors had visible possession of the lands in 1915 and had not received any notice.
  • The appl...continue reading

Jur is an AI-powered legal research platform in the Philippines for case digests, summaries, and jurisprudence. AI-generated content may contain inaccuracies; please verify independently.

© 2024 Jur.ph. All rights reserved.