G.R. No. L-2746 – 7 Phil. 132 – Civil Law – Land Titles and Deeds – Ancestral Domain – Ancestral Land Claim
Political Law – Regalian Doctrine
On June 23, 1903, Mateo Cariño went to the Court of Land Registration (CLR) to petition his inscription as the owner of a 146 hectare land he’s been possessing in the then municipality of Baguio. Mateo only presented possessory information and no other documentation. The State opposed the petition averring that the land is part of the US military reservation. The CLR ruled in favor of Mateo. The State appealed. Mateo lost. Mateo averred that a grant should be given to him by reason of immemorial use and occupation as in the previous cases Cansino vs Valdez and Tiglao vs Government; and that the right of the State over said land has prescribed.
ISSUE: Whether or not Mateo is the rightful owner of the land by virtue of his possession of it for some time.
HELD: No. The statute of limitations did not run against the government. The government is still the absolute owner of the land (regalian doctrine). Further, Mateo’s possession of the land has not been of such a character as to require the presumption of a grant. No one has lived upon it for many years. It was never used for anything but pasturage of animals, except insignificant portions thereof, and since the insurrection against Spain it has apparently not been used by Cariño for any purpose.
While the State has always recognized the right of the occupant to a deed if he proves a possession for a sufficient length of time, yet it has always insisted that he must make that proof before the proper administrative officers, and obtain from them his deed, and until he did the State remained the absolute owner.
Notes:
This case is closely related to the other Mateo Cariño vs Insular Government case promulgated on March 25, 1907.
This case was appealed to the U.S. Supreme Court. The latter reversed this decision (as well as the 1907 case): Full Text ¦ Case Digest
The decision laid down by the US Supreme Court was a landmark case which helped in the protection of indigenous communities.
