Case Summary (G.R. No. 86773)
Procedural History
On June 22, 1903, Carino filed a petition in the Court of Land Registration seeking registration as owner of the tract. The Insular and U.S. Governments opposed, asserting it lay within the Baguio military reservation. The Land Registration Court ruled for Carino. On appeal, the Court of First Instance of Benguet, sitting de novo, dismissed the petition. Carino prosecuted a bill of exceptions to this Court.
Factual Background
Carino’s only documentary evidence was a possessory information dated 1901, obtained under Article 394 of the Mortgage Law, which confers merely possessory rights. He offered no grant or patent from any sovereign. His contract with Clarke in 1901 acknowledged mere possession and contemplated sale upon acquisition of title. Possession had been sporadic, largely for pasturage, and ceased effectively after the Philippine insurrection against Spain.
Issue: Title by Possession
The core issue is whether prolonged possession of public agricultural land by an individual, without a governmental grant or patent, can ripen into title against the State by prescription or by conclusive presumption of grant.
Applicable Law: Possessory Information
Possessory information under the Mortgage Law creates no title beyond recognition of physical possession. It does not supply a legal source of ownership or vest rights superior to those of the State.
Non-Running of Statute of Limitations Against the State
This Court’s precedents (Valenton v. Murciano; Cansino v. Valdez; Tiglao v. Insular Government) establish that prescription and limitation statutes do not run against the sovereign in respect of its agricultural lands. Accordingly, mere occupancy, however long, does not outlast the State’s title.
Presumption of Grant: Limitations and Consistency
Carino asserted that immemorial use gives rise to a conclusive presumption of grant. The Court held that recognizing such a presumption would nullify the rule barring prescription against the State, producing an irreconcilable conflict. A presumption of grant is effectively a limitation statute; if one is denied, so must the other.
Incompatibility of Surrounding Circumstances with a Grant
Even if treated as a factual presumption, circumstances negate the likelihood of any grant:
- The Igorot population remained outside Spanish legal structures for centuries.
- No evidence indicates participation by Igorots in the formal land-grant processes prior to 1880.
- Carino himself sought formal title only in 1894, and his later contract disclaimed ownership.
Reliance on U.S. Precedents on Presumptive Grants
Carino invoked United States v. Chaves (159 U.S. 452; 175 U.S. 509) to support presumptive grants based on long possession. The Court distinguished those cases on the ground that either valid grants were proven to exist or circumstances supported inference of sovereign action. Here neither condition obtains.
Spanish Colonial Land-Title Regulations
Spanish law consistently required possessors of public lands to present title for adjustment or be evicted. Key enactments include:
- Royal Decree (1754)
Case Syllabus (G.R. No. 86773)
Facts
- On June 22, 1903, Mateo Carino, through his attorney‐in‐fact Metcalf A. Clarke, filed a petition in the Court of Land Registration to be inscribed as owner of a 14‐hectare tract in the municipality of Bagnio, Province of Benguet.
- The Philippine Insular Government and the Government of the United States appeared and opposed the petition, the latter claiming the land formed part of the military reservation of Baguio.
- The petitioner presented no documentary title except a 1901 possessory information under Mortgage Law, Art. 394, which conferred only the legal effects of mere possession.
- The land in dispute was agricultural and, according to evidence, had been used only for pasturage; no permanent habitation or cultivation by Carino or his predecessors was shown for many years.
Procedural History
- The Court of Land Registration rendered judgment in favor of Carino.
- Respondents appealed to the Court of First Instance of Benguet, where the case was tried de novo and the petition was dismissed.
- Carino brought the case before the Supreme Court by bill of exceptions.
Issues
- Whether mere possession of public agricultural land, evidenced by a possessory information, establishes title against the State.
- Whether immemorial possession gives rise to a conclusive presumption of grant by the Government.
- The applicability of Philippine precedents that hold the statute of limitations does not run against the St