Case Summary (G.R. No. 27818)
Background of Land Ownership
The petitioners assert their right to register the parcels of land based on a historical lineage of ownership beginning before American occupation. Tomas Roales initially took possession and cultivated the island and later acquired a grant from the Military Political Commander of Illana Bay between 1893 and 1895. Following the failure of the association known as Fortuna to settle land taxes, the land was auctioned off and acquired by Francisco Diaz, from whom the petitioners obtained the parcels in question.
Court's Findings on Land Parcels
The trial court granted registration for parcels 4, 6, 7, and 8, concluding they were cultivated and occupied by the petitioners and their predecessors ten years prior to American occupation. However, regarding parcel 2, the court ordered the petitioners to submit an amended plan, noting only a portion was occupied, while registration for the entirety of lot 3 was denied based on a lack of actual possession.
Legal Principles of Possession
The court's denial of registration for portion of lot 2 and all of lot 3 was predicated on the assertion that the applicants and their predecessors lacked actual possession. However, the petitioners contended that according to the precedent set in Ramos vs. Director of Lands, constructive possession could be claimed on the basis of cultivating a significant portion of the land. The legal principle clarified that one does not need physical presence on every square meter to establish possession; rather, possessing and cultivating a part of the land suffices as constructive possession of the whole if no adverse claim exists.
Reevaluation of Possession Claims
The Supreme Court evaluated the evidence, which indicated that the petitioners and their predecessors had actual possession of over two-thirds of Bonga Island. This substantial possession warranted a conclusion that constructive possession extended to the remaining
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Case Overview
- The case involves an application for the registration of various parcels of land on Bonga Island, located approximately 25 kilometers from Cotabato.
- The applicants, Roales Brothers and Cousins, claim ownership based on historical possession dating back to before American occupation.
- The land was cultivated by Tomas Roales, who received a grant from the Military Political Commander of Illana Bay between 1893 and 1895.
- The land was later sold at public auction due to non-payment of taxes, which led to its acquisition by Francisco Diaz, from whom the appellants obtained the parcels in question.
Historical Context and Initial Claims
- Tomas Roales initially entered into possession and began cultivating Bonga Island prior to the American occupation.
- The association known as Fortuna, formed by several individuals, was involved in the earlier claims to the land.
- The issues arose when Fortuna failed to pay the necessary land tax, leading to the auction and subsequent purchase of the land by Diaz.
Legal Proceedings and Lower Court Rulings
- The lower court recognized the applicants' claims to parcels 4, 6, 7, and 8, stating they had been occupied and cultivated for ov