Case Summary (G.R. No. L-2869)
Trial Court Findings
The registration court found that Carino’s predecessors had not possessed the entire 40-hectare area prior to his construction of a house around 1897–98. Testimony showed his earlier occupancy on adjacent private land, which he sold in 1893, before relocating to the present parcel. The court held that only a portion of the land was ever occupied and that the remainder was never subject to private egresion from the State.
Documentary Evidence and Possessory Information
Carino’s sole documentary proof was a possessory information filed March 7, 1901, covering 28 hectares limited by a barrio road. The court deemed this information insufficient to vest ownership, as it did not comply with the requirements for a royal‐decree title under Spanish law and covered less area than claimed.
Classification under Spanish Law and Royal Decree of 1894
Under Spanish sovereignty, unappropriated land of common origin presumptively belonged to the State. Title by composicion (adjustment) required meeting one of three conditions in Article 19 of the 1894 Decree: continuous cultivation for six years; possession for twelve years with recent cultivation; or thirty years’ uninterrupted possession. Carino’s land met none of these tests, and the one‐year verification window under Article 21 had lapsed, extinguishing any right to free title.
Public Lands under U.S. Sovereignty and Organic Act
With the Philippine Islands under American rule, unappropriated lands became “public lands,” alienable only by government grant per the Organic Act of 1902. Classification of alienable versus strictly public or forestry lands remained vested in the Government. Carino’s possessory information, not approved by the Government, conferred no ownership rights under the new regime.
Prescription under Act No. 627
Act No. 627 authorized acquisition of public lands by ten-year prescription for parcels not exceedi
...continue readingCase Syllabus (G.R. No. L-2869)
Facts of the Case
- On February 23, 1904, Mateo Carino petitioned the Court of Land Registration to register title over a 40-ha., 1-are, 13-centare parcel in Baguio, Benguet, including a wooden house roofed with rimo.
- The land was bounded: north by Sepa Carino, H. Phelps Whitmarsh, and Calsi (1,048 m 20 dm); east by Kuidno, Esteban Gonzales, and the Civil Government (991 m 50 dm); south by Talaca (115 m 60 dm); west by Sisco Carino and Mayengmeng (982 m 20 dm).
- Petition Nos. 561 (Carino) and 834 (Antonio Rebollo and Vicente Valpiedad) were consolidated: the latter claimed a small portion within Carino’s survey.
- The Insular Government opposed, asserting the land was public domain never alienated by Spain.
Procedural History
- The Court of Land Registration heard documentary and oral evidence.
- It found Carino’s possession was limited in time and extent and that he and predecessors never exclusively or adversely possessed the entire tract prior to house construction in 1897–1898.
- Both petitions were dismissed; the land was adjudged public.
- Carino appealed to the Supreme Court (G.R. No. 2869).
Evidence Presented
- Carino’s testimony and witnesses showed:
- In 1884 Carino built a house north of the present tract (Donaldson Sim’s property).
- In 1893 he sold that house to Cristobal Ramos, then to Sim, and moved to Whitmarsh’s adjoining land.
- Around 1897–1898 he relocated and built the house at the center of the claimed parcel, occupying part of it thereafter.
- Documentary evidence included a possessory information dated March 7, 1901 (registered March 11, 1901), claiming only 28 hectares bounded by the “country road to the barrio of Pias.”
Findings of the Court of Land Registration
- Carino’s predecessors and he did not possess the entire 40-ha. parcel exclusively or adversely before 1897–1898.
- Carino’s own possessory