Mateo Cariño vs The Insular Government (December 1906)

FACTS: 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.
Mateo Cariño vs The Insular Government (March 1907)

FACTS: In February 1904, Mateo Cariño filed a claim before the Court of Land
Registration praying that he be granted title over a 40 hectare land in the then town
of Baguio, Province of Benguet.

The government filed its opposition as it averred that Cariño or his predecessors in
interest did not continuously, exclusively, and adversely possessed the said parcel
of land. Cariño interposed that he and his ancestors had been in possession over
said parcel of land since time immemorial. And that in 1901, Cariño filed a claim
under the mortgage law over said parcel of land.

The government maintained that whatever right Cariño and his predecessors had
over the said parcel of land, the same had already prescribed by reason of their
failure to register their title during the Spanish Era. Under Spanish Law (specifically,
a decree issued in 1880), a land privately held, if not registered, shall revert back to
the public (regalian doctrine).

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

HELD: No. Cariño was not able to support his claim. As a rule, a parcel of land,
being of common origin, presumptively belonged to the State during its sovereignty,
and, in order to perfect the legitimate acquisition of such land by private persons, it
was necessary that the possession of the same pass from the State.

The parcel of land being contested here was not part of the lands disposed off
during the Spanish Era. The last disposition made by the Spanish government was
in 1894. The lands disposed in 1894 did not include the land being claimed
by Cariño hence, said land is presumed to belong to the State.

It is true that the American Government (which was then ruling the Philippines at the
time of this case) provided that prescription may favor a land claimant but only in
instances where the Spanish Government has allowed the claimant to cultivate an
unappropriated land. There was no showing that Cariño or his predecessors in
interest were allowed to cultivate said land (title of egresion or title of composicion).
In short, Cariño or his predecessors in interest failed to show that they were able to
comply with the legal requisites for them to acquire title.

His claim of title under the mortgage law is only possessory. He must wait for twenty
years to lapse before such can ripen to ownership.
MATEO CARIÑO vs. THE INSULAR GOVERNMENT OF THE PHILIPPINE
ISLANDS (1909 US Case)
FACTS:
 Carino is an Igorot of the Province of Benguet, where the land lies filed for writ of error
because the CFI and SC dismissed his petition for application

 For more than 50 years before the Treaty of Paris, April 11, 1899, he and his ancestors had
held the land as recognized owners by the Igorots. (grandfather maintain fences for holding
cattle>father had cultivated parts and used parts for pasturing cattle>he used it for pasture)

 1893-1894 & 1896-1897: he made an application but with no avail

 1901: petition alleging ownership under the mortgage law and the lands were registered to
him but process only established possessory title

 Even if the applicant have title, he cannot have it registered, because the Philippine
Commission's Act No. 926, of 1903, excepts the Province of Benguet among others from its
operation

ISSUE: W/N Carino has ownership and is entitled to registration.

HELD: YES. Petition Granted.
 Land was not registered, and therefore became, if it was not always, public land.

 Spanish Law: "Where such possessors shall not be able to produce title deeds, it shall be
sufficient if they shall show that ancient possession, as a valid title by prescription." For
cultivated land, 20 years, uninterrupted, is enough. For uncultivated, 30.

 Applicant's possession was not unlawful, and no attempt at any such proceedings against
him or his father ever was made.

 Every native who had not a paper title is not a trespasser.

 There must be a presumption against the government when a private individual claims
property as his or her own. It went so far as to say that the lands will be deemed private
absent contrary proof.