Mateo Cariño vs The Insular Government (February 1909)

written by Howard

212 U.S. 449 (41 Phil. 935) – Civil Law – Land Titles and Deeds – Ancestral Domain – Ancestral Land Claim

Political Law – Regalian Doctrine – Due Process – Property Rights

In 1903, Mateo Cariño filed a petition for him to be granted a certificate of title over a 40 hectare land in Baguio, Benguet. He claimed that he and his predecessors in interest had been in possession over said parcel of land since time immemorial; that the Igorot community where the said land was located had always considered Mateo Cariño and his predecessors/ancestors as the owner of said land; that said parcel of land had been transferred to his predecessors and unto him in accordance with the Igorot custom.

The land registration court granted his petition but the government through the Solicitor General opposed said grant on the ground that Mateo Cariño and ancestors failed to register said land during the Spanish Era. It was argued that in 1880, the Spanish government decreed that all privately held land must be registered or else they will be reverted back to the public domain (pursuant to the regalian doctrine).

The case reached the Philippine Supreme Court. The latter ruled against Mateo Cariño hence Cariño further appealed to the U.S. Supreme Court.

ISSUE: Whether or not Mateo Cariño’s claim should be granted.

HELD: Yes, the U.S. Supreme Court reversed the decision held by the Philippine Supreme Court. Mateo Cariño cannot be deprived of his land simply because he failed to comply with the formalities required by the Spanish law (or by a Philippine law). Cariño’s title, which he acquired from his ancestors predates, by more than 50 years, the establishment of the American government in the Philippines (in fact, even before the establishment of the Spanish government in the Philippines).

The US Supreme Court also noted that even the Solicitor General admitted that the Igorots were hardly ruled by the Spanish government. That being, it is unlikely that the Spanish government would grant land titles to the Igorots even if they will register their land under the old Spanish Law. The US Supreme Court also ruled that to follow the stand of the Solicitor General is to deprive the land titles of the natives (not only Igorots but all native inhabitants of the Philippine Islands). Under the Constitution: “no law shall be enacted in said islands which shall deprive any person of life, liberty, or property without due process of law, or deny to any person therein the equal protection of the laws.” The term “any person” includes the natives (in this case, the Igorots). All lands held under private ownership during the Spanish era shall therefore be presumed to be such. Failure to register under Spanish Law did not revert said lands to the public domain.

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