G.R. No. L-3637 - Roxas vs. Cuevas

On December 22, 1904, an application was filed with the Court of Land Registration by the petitioners for the registration of certain lands in the Province of La Laguna, known as the Hacienda of Calauang, which measured 7,813 hectares and 87 ares and was valued at $525,000 in United States money.
The application was opposed by several parties:

The Government of the Philippine Islands, represented by the Attorney-General.
Residents of Calauang (367 individuals represented by Jose Santiago).
Residents of the ancient town of Alaminos (136 individuals, now part of San Pablo, La Laguna) and three residents of Santo Tomas, Batangas, represented by Juan Alvarez.
80 residents of San Pablo, La Laguna, represented by Julian Gerona and Gregorio Pineda.

The lands were originally Crown lands of the Kingdom of Spain and were conveyed by a royal grant dated February 2, 1777, to Francisco Xavier Salgado, who took possession on March 5, 1776.
After Salgado’s death, his estate came under the administration of the Auditoria de Guerra, leading to an auction sale on February 7, 1829.
Benito Machado purchased the hacienda for 16,000 pesos (half paid in cash, half deferred with a mortgage provided to secure the balance).
The purchase funds were managed in the name and for the benefit of Domingo Roxas, who completed the payment conditions, thereby acquiring fee simple title to the hacienda.
Through subsequent mesne conveyances and regular succession, the title passed to the petitioners, who held it free and clear of all incumbrances except for a 'censo' lien dated February 26, 1834, for twelve thousand pesos with 6% annual interest.

Active and continuous possession was maintained for over 130 years by Francisco Xavier Salgado and his successors through actual occupancy: construction of buildings, cultivation, appointment of administrators, collection of rents, surveys, placing boundary monuments, and periodic inspections.
Judicial proceedings in 1847, 1848, 1878, and 1880 addressed disputes over boundaries, using surveys and an official plan (Exhibit U) to confirm the true boundaries of the hacienda as determined by the courts and recognized by the Government.
Evidence also showed that when aggressions upon the owners' rights occurred, legal proceedings resulted in judgments affirming the ancient title and possession of the petitioners.

The petitioners legally acquired and held fee simple title to the Hacienda of Calauang.
Possession had been continuous and effective, confirmed by judicial decrees and surveys, and was not merely constructive.

On the same day, respondents (residents of Calauang) excepted to the judgment and filed a motion for a new trial, challenging the sufficiency of evidence supporting the petitioners' claim.
The respondents, through their bill of exceptions, raised issues including:

The admission of certain exhibits (Exhibits C and D) concerning the auction sale and subsequent transactions.
The sufficiency and continuity of evidence establishing the chain of title.
The inquiry into whether the land was actually Government property, based on homestead applications and internal agreements.
The argument that the petitioners’ possession was only evidential of mere possession, allegedly forfeited by the absence of actual occupancy for more than eight years.

The exclusion of certain tracts initially not covered by the February decision.
An adjudication awarding approximately 787 hectares to the petitioners, while about 213 hectares were determined to be public forest.

Additional appeals and motions for new trials were filed by Attorney Santiago and others, focusing on the legal interpretation of evidence and the proper standing of the respondents to challenge the registration.

At the time of entry by respondents, the land was lawfully possessed by the petitioners under a valid title.
Possession by the petitioners, as demonstrated by active occupancy and judicial recognition, was unbroken.
Respondents’ claims largely depended on showing permissive use rather than exclusive and continuous possession.

The respondents also contested the involvement of Government actions (e.g., homestead applications and permits) in affecting the petitioners’ title—alleging that the land belonged to the Government.
The appellate review was confined to issues of law, notably because the procedural posture (orders for a new trial and exceptions) did not warrant a reexamination of the trial court’s factual findings.

Whether the continuous and active possession over the Hacienda of Calauang, as shown by the petitioners’ extensive evidence, sufficiently established their legal title.
Whether the admission of certain evidentiary exhibits (Exhibits C and D) was proper and whether they effectively corroborated the chain of title from the original grant through subsequent conveyances.
Whether respondents’ claims regarding the land’s status as Government property and the alleged preferential rights of homesteaders should have affected the registration of the petitioners’ title.
Whether the respondents, as private citizens and not having standing to assert a government interest, could legitimately challenge the grant of title based on the alleged lapse in possession.
Whether procedural issues regarding the motion for a new trial and the bill of exceptions (and the associated evidentiary submissions) justified setting aside the trial court’s findings of fact.