Case Summary (G.R. No. 73261)
Procedural Background
- 1961–62: Belong Lutes petitions the CFI to reopen Civil Reservation Case No. 1, alleging adverse, continuous possession since Spanish times and lack of notice to Igorot predecessors.
- Private petitioners and City of Baguio file oppositions, asserting valid tree-farm leases executed in 1959.
- CFI initially denies private petitioners’ intervention (March 9, 1962 judgment invalidating leases against non-parties), reverses itself (September 14, 1962), then dismisses their opposition (August 5, 1963; denial of reconsideration on November 5, 1963).
- City of Baguio and Reforestation Administration file motion to dismiss reopening for lack of jurisdiction; denied September 17, 1964.
- Petitioners secure preliminary injunction and appeal to Court of Appeals, which holds on September 30, 1965 that private lessees lack standing to oppose reopening.
- Petitioners elevate to the Supreme Court by certiorari; cause given due course August 12, 1966.
Issue 1: Standing of Private Lessees under RA 931
• RA 931 confines reopening to parcels “not… leased… or otherwise… disposed of by the Government.”
• Lessees’ interest in existing leases is “intrinsically dependent” on government title but sufficient to bar reopening.
• Unlike ordinary land registration oppositions (Leyva v. Jandoc), RA 931 implicitly recognizes the lessee’s right to oppose because the statute withdraws from reopening any land already leased.
• Under Rules of Court, persons with “legal interest in the matter” may intervene.
Conclusion: Private petitioners, as government tree-farm lessees who introduced improvements, have personality to intervene and oppose Lutes’ petition.
Issue 2: Publication Requirement for Reopening Petition
• Reopening petitions under RA 931 are sui generis and concern land already within cadastral jurisdiction.
• De Castro v. Marcos (Jan. 27, 1969) held that no publication is required when the property was part of the original cadastral case.
• Lutes’ petition invoked the same 1912 proceedings; petitioners did not dispute that fact.
Conclusion: The cadastral court’s jurisdiction over the reopening was not vitiated by failure to publish the petition.
Issue 3: 40-Year Limitation and Statutory Interpretation of RA 931
• Title of RA 931 authorizes claims “by virtue of judicial decisions rendered within the forty years next preceding the approval of this Act”; Section 1 refers to proceedings “instituted within the forty years.”
• Constitutional requirement (1935 Constitution, Art. VI, Sec. 21[1]) demands the subject be expressed in the title.
• Remedial statutes carry a presumption in favor of liberal construction to effect legislativ
Case Syllabus (G.R. No. 73261)
Facts
- In 1912, the Director of Lands instituted Civil Reservation Case No. 1 (GLRO Record No. 211, Baguio Townsite) in the CFI of Baguio; final decision declaring certain parcels as public lands issued November 13, 1922
- On July 25, 1961, Belong Lutes petitioned to reopen the cadastral proceedings under R.A. 931, claiming adverse, continuous possession since Spanish times and lack of notice to his illiterate Igorot predecessors
- December 18, 1961, private petitioners Joaquin, Sr., Joaquin, Jr., and Buchholz opposed, asserting they held tree farm leases (granted in 1959 by the Bureau of Forestry) covering portions of the same land
- May 5, 1962, City of Baguio also filed opposition
- May 8, 1962, cadastral court denied private petitioners’ intervention, citing a declaratory judgment in Yaranon vs. Castrillo (CIVIL CASE 946) nullifying their leases
- September 14, 1962, cadastral court reversed and permitted cross-examination; subsequent pleadings followed, leading to August 5, 1963 dismissal of private petitioners’ opposition and denial of reconsideration on November 5, 1963
- January 6, 1964, City of Baguio moved to dismiss Lutes’ reopening petition; motion adopted by Reforestation Administration; opposed by Lutes on February 24, 1964; consolidated motions denied September 17, 1964
- November 13, 1964, all petitioners elevated the case to the CA via certiorari, prohibition, and mandamus; CA issued preliminary injunction and on September 30, 1965 held private petitioners lacked standing as lessees to oppose; motion for reconsideration denied May 6, 1966
- Petitioners filed certiorari before the Supreme Court; respondents moved to dismiss on July 6, 1966; SC gave due course on August 12, 1966
Procedural Issues
- Whether private petitioners (tree farm lessees) have personality to intervene in a reopening petition under R.A. 931
- Whether t