G.R. No. L-32941 - Republic vs. Marcos

The petition for review on certiorari was filed by the Republic of the Philippines against the decision of respondent Judge Pio R. Marcos of the Court of First Instance of Baguio, Branch I.
The case involved a petition to reopen Civil Reservation Case No. 1, originally establishing the Baguio Townsite Reservation promulgated on November 13, 1922.
On November 12, 1966, the private respondents (the Carantes heirs) filed a petition for reopening the case, seeking declaration of ownership and registration of four lots covering 74,017 square meters inside Camp John Hay.
On December 14, 1966, respondent Judge ordered the publication and posting of notices as required in the reopening process.
Despite opposition from the Director of Lands—who had submitted a report indicating that the area was within Camp John Hay—the respondent Judge rendered a decision on November 9, 1968, ordering registration of the lots in favor of the private respondents.
Efforts by the Director of Lands and the City of Baguio to appeal the decision were frustrated by the respondent Judge’s determination that only Camp John Hay, and not these officials, was the proper party to appeal.
It was not until August 22, 1969, that the Solicitor-General entered the case and, on December 8, 1969, his motion to annul the decision on grounds of lack of jurisdiction (since the land is part of a military reservation) was denied by the same respondent Judge.

The land subject to the proceedings is a part of Camp John Hay, a duly established military camp or reservation.
The disputed area had been initially reserved for military and naval purposes via historical executive orders—beginning with an executive order issued by U.S. President William H. Taft on October 10, 1910, and later by President Herbert Hoover on June 19, 1929.
The submission of private claims for registration was based on the contention that the Carantes heirs had been in possession of the land “since the Spanish regime,” citing survey plan annotations stating “subject to prior and existing private rights.”

The applicability of Republic Act No. 931, as amended by Republic Act 2061, was central to the proceedings. This law provides that only persons claiming title to parcels that have been the object of cadastral proceedings—with actual possession at the time of the survey—may petition for reopening of such proceedings, provided that the parcels have not been disposed of by the Government.
The decision in Republic vs. Marcos (L-29675, September 30, 1969, 29 SCRA 517) was noted as authoritatively precluding the reopening of a case that is not a cadastral proceeding, particularly when the land in question is within a military reservation.
Historical statutes and earlier decisions—including Government vs. Court of First Instance of Pampanga (1926) and Jose vs. Commander of the Philippine Squadron (1910)—supported the view that re-opening is inappropriate where public lands designated for military purposes are involved.

Whether the respondent Judge had the authority to reopen Civil Reservation Case No. 1, given that the proceedings were not cadastral in nature and the subject matter involved land within a military reservation.
Whether Republic Act No. 931 can be applied to the disputed lots in Camp John Hay.

The extent to which the limitations in Republic Act No. 931 restrict the reopening of cadastral proceedings to lands that have not been alienated, reserved, leased, or otherwise disposed of by the Government.
Whether the private respondents’ claim, based on their alleged long possession and the annotation “subject to prior and existing private rights,” could override the statutory limitations for lands reserved for military use.

Whether the private respondents can invoke the doctrine of estoppel, relying on alleged previous representations or actions by government officials, to support their claim against the state.