Case Summary (G.R. No. 13298)
Key Dates
1882 – Romero’s initial occupation
1894–1896 – Acquisition of possessory information title under the Maura Law
February 1907 – Sale of parcel to Ramos
July 26, 1904 – Cut-off date for ten-year possession under Public Land Law
1917 – Administrative Code forestry provisions
November 19, 1918 – Decision date (applicable law: Royal Decree 1894; Act No. 926 as amended by Act No. 1908; Philippine Bill of July 1, 1902)
Procedural History
Ramos filed for registration of Parcel No. 1 under the Land Registration Act. The Director of Lands opposed on the ground that Ramos’s Spanish title was defective; the Director of Forestry asserted the tract was “forest land.” The Court of First Instance denied registration of areas marked A, B, and C. Ramos appealed.
Possessory Title Under the Royal Decree of February 13, 1894
Under Spanish Mortgage Law and the Maura Law, possession required six years’ cultivation and exclusion of forest land. Although mature trees (50–80 years old) suggested a forestal character, the Court deemed it unnecessary to disturb the registered possessory information because Ramos’s predecessor held color of title in good faith.
Ten-Year Presumption of Title (Act No. 926, § 54(6), as Amended)
Act No. 926 (Public Land Law) conclusively presumes grantable title in those who, under color of title, have had open, continuous, exclusive, and notorious possession of agricultural public land for ten years preceding July 26, 1904. Ramos’s cultivation of roughly one-quarter of Parcel No. 1 invoked the doctrine of constructive possession, which treats partial occupation under claim of the whole tract as possession of the entire tract, absent competing claims.
Classification of Lands: Agricultural vs. Forest (Philippine Bill, §§ 13–18)
The Philippine Bill defines three categories: public (domain) lands, mineral lands, and timber lands. Section 18 instructs that lands more valuable for agricultural uses than forest uses qualify as agricultural public lands. Precedents (Jones v. Insular Government; Mapa v. Insular Government) have construed agricultural public lands as all non-timber, non-mineral public lands.
Forestry Certification Requirement (Administrative Code 1917, §§ 1820, 1827)
The Administrative Code entrusts the Director of Forestry with certifying whether unreserved public lands are better suited for agriculture or forestry. No such certification appeared in the record. Expert evidence must accompany any opposition to private claims, yet the Director’s formal opposition lacked the requisite on-site technical proof.
Balancing Private Title and Natural-Resource Conservation
While conservation of forest resources is a paramount policy
...continue readingCase Syllabus (G.R. No. 13298)
Facts
- Restituto Romero y Ponce obtained possession of a large tract in San Jose, Nueva Ecija, in 1882.
- He secured a possessory information title under the Royal Decree of February 13, 1894, registered February 8, 1896.
- Parcel No. 1 of Romero’s title, marked A, B, and C on Plan Exhibit 1, was sold in February 1907 to Cornelio Ramos and his wife.
- Ramos initiated registration proceedings for the entire parcel.
- The Director of Lands objected, alleging Ramos’s Spanish title was defective.
- The Director of Forestry also objected, claiming Parcel No. 1 was forest land.
- The Court of First Instance of Nueva Ecija sustained both objections and excluded the parcel from registration.
- Ramos appealed to the Supreme Court.
Procedural History
- Trial Court (C. F. I. Nueva Ecija): Denial of registration for Parcel No. 1.
- Supreme Court: Review by Malcolm, J., on appeal from the trial court’s judgment.
Issue
- Whether Ramos, through Romero’s possessory title and his own open, continuous, exclusive, and notorious possession, is entitled to registration of the entire Parcel No. 1 under subsection 6, section 54, Act No. 926 as amended by Act No. 1908.
Applicable Law
- Spanish Mortgage Law and Royal Decree of February 13, 1894 (Maura Law) – prerequisites for posses