Mateo Carino (plaintiff in error) vs.

Insular Government of the Philippines (defendant in

error)212 US 449, 41 Phil Justice Holmes How it reached the court:Plaintiff applied for registration of a certain land. Initially it was granted
by the court, but the Government of the Philippines and the government of the United states
appealed to the Court of first instance of Benguet (they were taking the property for public and
military purposes. The CFI dismissed the application (for registration) and this was affirmed by
the Philippine Supreme Court. This was brought to the US Supreme court by writ of error.
Facts:-Plaintiff, an Igorot, possessed the land for more than 30 years before the
treaty of Paris. He and his ancestors had held the land for years. The local community
recognizes them as the owners of the said land. His grandfather lived upon it and maintained
fences around the property. His father raised cattle on the property and he had inherited the land
according to Igorot custom. Although no title was issued to them from the Spanish Crown. He
tried twice to have it registered during the Spanish occupation but to no avail. In 1901 he filed a
petition alleging ownership of the land but he was only granted a possessory title.
Issues:
1.) Whether the mode of reaching the US supreme court was right (this was a writ of error,
some were saying that it should have been an appeal) Holmes said that the mode was
correct. Writ of error was the general rule, appeal is the exception. He saw no reason not
to apply the general rule to this case.
2.) Another issue was that even if Carino was able to have a title over the land, he could not
have it registered because Benguet was one of the excluded provinces in the Philippine
Commissions act no. 926 (AN ACT PRESCRIBING RULES AND
REGULATIONSGOVERNING THE HOMESTEADING, SELLING, AND
LEASING OF PORTIONS OF THEPUBLIC DOMAIN OF THE PHILIPPINE
ISLANDS). But that law dealt with acquisition of new titles and perfecting of titles
begun under the Spanish law. Carino argued that he could register the land under
Philippine Commissions Act no. 496 which covered the entire Philippine archipelago.
Holmes held that he could register the land if ownership can be maintainedMain issue: whether Carino owns the land.
Governments argument: Spain had title to all the land in the Philippines except those it
saw fit to permit private titles to be acquired. That there was a decree issued bySpain that
required registration within a limited time. Carinos land wasnt registered and so in effect it
became public land.
USSC: Whatever the position of Spain was on the issue, it does not follow that the US
would view plaintiff to have lost all his rights to the land this would amount to a denial of
native titles throughout Benguet just because Spain would not have granted to anyone in the
province the registration of their lands.

Organic act of July 1, 1902 provides that all the property and rights acquired there by the
US would be for the benefit of the inhabitants thereof. This same statute made a bill of rights
embodying the safeguards of the constitution, it provides that '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. It would be hard to believe that any
person didnt include the inhabitants of Benguet. Nor it meant property to refer only to those
lands which had become such under a ceremony (of registration) many of the people of the land
may have not even heard of. Although in sec. 14 of the organic act, it is said that the Philippine
commission may prescribe rules and regulations for perfecting titles to public lands, it should be
noted that this section refers to those cases where the land was admitted to be public land. The
US SC hesitates to suppose that it was intended to declare every native who had not a paper title,
a trespasser. The question still remains: what property and rights did the US acquire? In cases
like this one, the presumption would and should be against the government. As far back as
memory goes, the land has been held by individuals under a claim of private ownership, it was
never public land. It would not be proper to just let the conqueror to dictate how to deal with the
Philippine tribes if it really meant to use the rights acquired by them for the benefit of the
inhabitants thereof. The natives were recognized by the Spanish laws to own some lands,
irrespective of any royal grant. They didnt intend to turn all the inhabitants into trespassers.
Principle of prescription was admitted: that if they werent able to produce title deeds, it is
sufficient if they show ancient possession, as a valid title by prescription. Although there was a
decree in June 25, 1880 that required everyone to get a document of title or else lose his land, it
does not appear that it meant to apply to all but only those who wrongfully occupied royal lands.
IT doesnt appear that the land of Carino was considered as Royal land nor was it considered to
have been wrongfully occupied. Two articles of the same decree provided that titles would be
attributed to those who may prove possession for the necessary time. There were indications that
registration was expected but it didnt mean that ownership actually gained would be lost. The
effect of the proof was not to confer title to them but to establish it.
Law and justice require that the applicant should be granted what he seeks and should not be
deprived of what, by the practice and belief of those among whom he lived, was his property,
through a refined interpretation of an almost forgotten law of Spain. Judgment reversed.

FRANCISCO I. CHAVEZ, petitioner, vs. PUBLIC ESTATES AUTHORITY and

AMARI COASTAL BAY DEVELOPMENT CORPORATION, respondents.
President Marcos through a presidential decree created PEA (Public Estate
Authority), which was tasked with the development, improvement, and acquisition,
lease, and sale of all kinds of lands. The then president also transferred to PEA the
foreshore and offshore lands of Manila Bay under the Manila-Cavite Coastal Road

and Reclamation Project. Thereafter, PEA was granted patent to the reclaimed
areas of land and then, years later, PEA entered into a JVA (Joint Venture
Agreement) with AMARI for the development of the Freedom Islands. These two
entered into a joint venture in the absence of any public bidding.
__1988: Pres. Aquino issued Special Patent granting and transferring to PEA
parcels of land so reclaimed under the MCCRRP. Subsequently she
transferred in the name of PEA the three reclaimed islands known as the
Freedom Islands
__1995: PEA entered into a Joint Venture Agreement (JVA) with AMARI, a
private corporation, to develop the Freedom Islands and this was done
without public bidding
__Pres. Ramos through Executive Secretary Ruben Torres approved the JVA
Later, a privilege speech was given by Senator President Maceda
denouncing the JVA as the grandmother of all scams. An investigation was
conducted and it was concluded that the lands that PEA was conveying to AMARI
were lands of the public domain; the certificates of title over the Freedom Islands
were void; and the JVA itself was illegal. This prompted Ramos to form an
investigatory committee on the legality of the JVA. Petitioner now comes and
contends that the government stands to lose billions by the conveyance or sale of
the reclaimed areas to AMARI. He also asked for the full disclosure of the
renegotiations happening between the parties. The petition seeks to compel the
Public Estates Authority ("PEA") to disclose all facts on PEA's then on-going
renegotiations with Amari Coastal Bay and Development Corporation ("AMARI")
to reclaim portions of Manila Bay. The petition further seeks to enjoin PEA from
signing a new agreement with AMARI involving such reclamation. PEA asserts
that in cases of on-going negotiations the right to information is limited to definite
propositions of the government." PEA maintains the right does not include access
to "intra-agency or inter-agency recommendations or communications during the
stage when common assertions are still in the process of being formulated or are in
the 'exploratory stage'."
ISSUE: W/N stipulations in the amended JVA for the transfer to AMARI of
the lands, reclaimed or to be reclaimed, violate the Constitution.
HELD: The ownership of lands reclaimed from foreshore and submerged areas is
rooted in the Regalian doctrine, which holds that the State owns all lands and
waters of the public domain.
The 1987 Constitution recognizes the Regalian doctrine. It declares that all
natural resources are owned by the State and except for alienable

agricultural lands of the public domain, natural resources cannot be

alienated.The Amended JVA covers a reclamation area of 750 hectares. Only
157.84 hectares of the 750 hectare reclamation project have been reclaimed, and
the rest of the areas are still submerged areas forming part of Manila Bay. Further,
it is provided that AMARI will reimburse the actual costs in reclaiming the
areas of land and it will shoulder the other reclamation costs to be incurred.
The foreshore and submerged areas of Manila Bay are part of the lands of the
public domain, waters and other natural resources and consequently owned by
the State. As such, foreshore and submerged areas shall not be alienable unless
they are classified as agricultural lands of the public domain. The mere
reclamation of these areas by the PEA doesnt convert these inalienable natural
resources of the State into alienable and disposable lands of the public domain.
There must be a law or presidential
proclamation officially classifying these reclaimed lands as alienable and
disposable if the law has reserved them for some public or quasi-public use.

BUENAVENTURA V. REPUBLIC (LTD)

Confirmation of Imperfect Title
Application for registration of title before the RTC, whether personally or through duly
authorized representatives: Who may file?1.Those who, by themselves or their
predecessors-in-interest:
_have been in OPEN, CONTINUOUS, EXCLUSIVE, AND NOTORIOUS possession and
occupation of the subject land;
_which land must be ALIENABLE and DISPOSABLE land of public domain; and
_that such possession must be under a bona fide claim of ownership since 12 June 1945 or
earlier; and
2. Those who have acquired ownership of private lands by PRESCRIPTION under the
provisions of law.

Petitioners Angelita and Preciosa are the applicants for registration of title
over the subject property. They are the heirs of spouses Amado Buenaventura and
Irene Flores (spouses Buenaventura) from whom they acquired the subject
property.The subject property was acquired by the spouses Buenaventura from the
Heirs of Lazaro de Leon, before World War II. However, it was only on 30 January

1948 that the corresponding Deed of Sale4 was executed in favor of the spouses
Buenaventura.
An Application for Registration of Title on 5 June 2000 were filed before the
RTC of Paranaque wherein petitioners presented witnesses in order to establish the
fact that petitioners and their predecessors have acquired vested right over the
subject property in the manner and for the period required by law; likewise, to
prove the alienable and disposable character of the property since 3 January 1968
as certified by the DENR. RTC granted the petition.
Republic appealed to the Court of Appeals alleging that petitioners failed to
prove continuous, open, exclusive and notorious possession by their predecessorsin-interest and by themselves. The CA reversed the trial courts decision and
declared the subject property a public land.
ISSUES:
I. Whether or not the Court of Appeals erred in nullifying the Decision of the trial
court confirming petitioners title over the subject property for not being allegedly
supported by substantial evidence as required by law. (YES)
II. Whether or not the Court of Appeals gravely erred in declaring the subject
property as public land and ignoring petitioners evidence of over 30 year
possession in the concept of an owner and completely unmolested by any adverse
claim. (YES)
HELD:
Petitioners offered in evidence a certification from the Department of Environment
and Natural Resources, to prove that the subject property was alienable and
disposable land of the public domain. Such certification is sufficient, in the absence
of contrary evidence, to prove the character of the land.
Furthermore, petitioners were able to prove sufficiently (through their witnesses)
that they have been in possession of the subject property for more than 30 years,
which possession is characterized as open, continuous, exclusive, and notorious, in
the concept of an owner. By this, the subject alienable and disposable public land
had been effectively converted into private property over which petitioners have
acquired ownership through prescription to which they are entitled to have title
through registration proceedings. Petitioners right to have their title to the subject
property registered cannot be defeated simply because the possession of petitioners
commenced on a date later than 12 June 1945, for the law and supplementing

jurisprudence amply, justly and rightfully provides the necessary remedy to what
would otherwise result in an unjust and unwarranted situation. It would be the
height of injustice if petitioners registration of title over the said property will de
denied solely on that ground.
(Note: The court granted the petition for registration based on Sec. 14 Par. 2 of
PD 1529)
Cruz v Executive Secretary347 SCRA 128
Facts of the Case:
RA 8371 was assailed as unconstitutional on the ground that it deprived
the State of itsownership over lands of the public domain and the natural resources
in them. RA 8371 definedwhat are ancestral domains and ancestral lands.
Issue:
Whether or not RA 8371 is unconstitutional?
Held:
No.Ratio: The vote was 7-7 which meant that validity was upheld. The
opinion defending constitutionality held the following: (1) ancestral domain and
ancestral lands are not part of lands of the public domain. They are private and
belong to indigenous people. Section 5 commands the state to protect the rights of
indigenous people. Cario v. Insular Government recognized native title held by
Filipinos from time immemorial and excluded them from the coverage of jura
regalia. (2)The right of ownership granted does not include natural resources. The
right to negotiate terms and conditions over natural resources covers only
exploration to ensure environmental protection. It is not a grant of exploration
rights. (3) The limited right of management refers to utilization as expressly
allowed in Section 2, Article XII. (4) What is given is priority right, not exclusive
right. It does not preclude the State from entering into co-production, joint venture,
or production sharing agreements with private entities. The opinion assailing the
constitutionality of the law held the following: (1) the law amounts to
an abdication of state authority over a significant area of the countrys patrimony;
(2) It Relinquishes full control of natural resources in favor of indigenous
people; (3) the law contravenes the provision which says that all natural resources
belong to the state.