1) Mateo Cariño, an Igorot from Baguio, Benguet, owned 40 hectares of land that had been passed down through his family for generations according to Igorot custom.
2) When Cariño applied for a formal land title, his petition was denied by the Court of Land Registration and Philippine Supreme Court.
3) The US Supreme Court reversed the lower court rulings, finding that long-term occupation and recognition of ownership by the local community established Cariño's private ownership, overriding the Spanish legal doctrine of state ownership of undocumented lands. The denial of Cariño's title violated his right to due process under the Organic Act of 1902
1) Mateo Cariño, an Igorot from Baguio, Benguet, owned 40 hectares of land that had been passed down through his family for generations according to Igorot custom.
2) When Cariño applied for a formal land title, his petition was denied by the Court of Land Registration and Philippine Supreme Court.
3) The US Supreme Court reversed the lower court rulings, finding that long-term occupation and recognition of ownership by the local community established Cariño's private ownership, overriding the Spanish legal doctrine of state ownership of undocumented lands. The denial of Cariño's title violated his right to due process under the Organic Act of 1902
1) Mateo Cariño, an Igorot from Baguio, Benguet, owned 40 hectares of land that had been passed down through his family for generations according to Igorot custom.
2) When Cariño applied for a formal land title, his petition was denied by the Court of Land Registration and Philippine Supreme Court.
3) The US Supreme Court reversed the lower court rulings, finding that long-term occupation and recognition of ownership by the local community established Cariño's private ownership, overriding the Spanish legal doctrine of state ownership of undocumented lands. The denial of Cariño's title violated his right to due process under the Organic Act of 1902
221 U.S. 449 (1909) Holmes, J. reversing Phil. S.Ct. 7 Phil. 132 (1907)
TOPIC. Due process clause: 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. (12, Organic Act of 1902)
FACTS. Mateo Cario (MC), an Igorot from Baguio, Benguet, owns 40 ha. of land therein. He and his ancestors had held the land as owners and were recognized as owners by the Igorots, but no document of title was issued under Spanish Crown. MC filed petition for title at Court of Land Registration (CLR) on Feb. 1904; denied. Appealed to Phil. S.Ct.; denied (Mar. 1907). Thus appeal to court a quo.
ISSUE. Whether plaintiff MC owns the land
RESOLUTION. MC owns the land. Reversed.
ARGUMENTS & HOLDING
INSULAR GOVT argued: Spain assumed and had title to all land in PH, save permitted private titles. MCs land was not registered, and therefore became, if it was not always, public land. US succeeded to the title of Spain (see Treaty of Paris, 30 Stat. 1754 (1899)). Thus, MC has no rights that the government is bound to respect. (Regalian doctrine)
MC claimed: He and his ancestors had held the land as owners. His grandfather had lived upon it according to the custom of the country, as had his father. They all had been recognized as owners by the Igorots, and he had inherited or received the land from his father, in accordance with Igorot custom. THE COURT held unanimously: Presumption against Government. Every presumption of ownership is in favor of one actually occupying land for many years, and against the government which seeks to deprive him of it, for failure to comply with provisions of a subsequently enacted registration act.
Land held since time immemorial is private; exception to Regalian doctrine. While 14 of Organic Act of 1902 empowers Ins. Govt. to enact rules and prescribe terms for perfecting titles to public lands issue patents to natives for public lands, this section is confined to cases where the occupation was of land admitted to be public land and had not continued for such a length of time and under such circumstances as to give rise to the understanding that the occupants were owners at that date.
Ins. Govt. contention a denial of due process. The Organic Act of the Philippines made a bill of rights embodying safeguards of the Constitution, and, like the Constitution, extends those safeguards to all. One who actually owned land for many years cannot be deprived of it for failure to comply with certain ceremonies prescribed either by the acts of the Philippine Commission or by Spanish law. AC
Cessions of Land by Indian Tribes to the United States: Illustrated by Those in the State of Indiana
First Annual Report of the Bureau of Ethnology to the Secretary of the Smithsonian Institution, 1879-80, Government Printing Office, Washington, 1881, pages 247-262
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