Reavis vs.

Fianza
40 Phil 1017
Facts:
The appellees, Fianza et al., are Igorots. Fianza and his ancestors have held
possession of certain gold mines in the Province of Benguet for fifty years or
probably more. They owned the mines in question and they were claiming title
under the Philippine Act of July 1, 1902. They had all worked the mines, that no
one else had claimed them, and that the appellant, Reavis, had interfered with
their possession.
In 1900, Reavis, a Westerner, illegally entered and deprived the appellees
of their mines, and that he still continues to maintain his unjust claim. Fianza
brought an action to restrain Reavis from setting up title to certain gold mines in
the Province of Benguet, or interfering with the same, and to obtain an account of
the gold taken from the mines.
The trial court rendered a judgment enjoining the setting up of title to
certain gold mines in the province or decree granting an injunction as prayed. The
Supreme Court of the Philippines reexamined the evidence and affirmed the
decree. The case was then appealed to the Supreme Court of the United States.
Issue:
Whether or not setting up of title to the gold mines and the interposed
adverse claim are tenable.
Ruling:
It was held that there was no adverse claim that would have prevented
Fianza et al. from getting a patent under Section 45 of the Philippine Act of July 1,
1902. The provision states that were such person or association, they and their
grantors have held and worked their claims for a period equal to the time
prescribed by the statute of limitations of the Philippine Islands, evidence of such
possession and working of the claims for such period shall be sufficient to
establish a right to a patent thereto under this Act, in the absence of adverse
claim; but nothing in this Act shall be deemed to impair any lien which may have
attached in any way whatever prior to the issuance of the patent.
It was suggested that the possession was not under the claim of title, since
they could have no title under Spanish law. But the Act cannot be taken to adopt
from the local law any other requirement as to the possession other than the
length of time for which it was be maintained. Section 16 of the Act shows the
intention of Congress to respect native occupation of public lands. It is urged that
the section confers no right other than to apply for a patent. But a right to an
instrument that will confer a title in a thing is a right to have the thing. That is to
say, it is a right of the kind that specifically enforces. It may or may not be true
that, if the objection had been taken at the outset, Fianza et al. would have been
turned over to another remedy and left to apply for a patent; but after trial on the
merits, the objection comes too late.
The Court found no sufficient ground to reverse the decree, and it was
affirmed.