27 Scra 342

27 SCRA 342 City of Baguio, ET AL. vs. PIO R. MARCOS, ET AL.G.R. No. L-26100 February 28, 1969Sanchez, J.
FACTS: On April 12, 1912 , the Director of Lands in the Court of First Instance of Baguio instituted the reopening of cadastral proceedings (a land registration/ titling proceeding) Civil Case No.1. A decision on November 13, 1922 was rendered ; the land involved (Baguio Townsite) was among those declared public lands. On July 25, 1961, Belong Lutes petitioned cadastral court to reopen said civil case. He claims that the land (Baguio Townsite) be registered in his name upon the grounds that 1.) he and his predecessors have been in continuous possession and cultivation of the land since Spanish times 2.) his predecessors were illiterate Igorots, thus were not able to file their claim to the land in question. On the other hand, Francisco G. Joaquin Sr., Francisco G. Joaquin, Jr. and Teresita J. Buchholz, as tree farm lessees of the land in question, opposed the reopening. Their contentions are as follows: 1.) The reopening petition was filed outside the 40-year period provided by R.A. 931 2.) Petition to reopen the case was not published 3.) as lessees of the land, they have a standing to appear in there opening proceedings. ISSUE/S: Statcon issue here is whether the reopening petition was filed outside the 40-year period provided by R.A. 931 (enacted June 20,1953). Joaquins group contests that the title of the said act is in conflict with section 1 of the same act, thus invalidating the petition of Lutes to reopen the civil case. Title of the act reads: AN ACT TO AUTHORIZE THE FILING IN THE PROPER COURT, UNDER CERTAIN CONDITIONS, OF CERTAIN CLAIMSOF TITLE TO PARCELS OF LAND THAT HAVE BEEN DECLARED PUBLIC LAND, BY VIRTUE OF JUDICIAL DECISIONS RENDERED WITHIN THE FORTY YEARS NEXT PRECEDING THE APPROVAL OF THIS ACT. Section 1 of the act provides: SECTION 1. in case such parcels of land, on account of their failure to file such claims, have been, or are about to be declared land of the public domain by virtue of judicial proceedings instituted within the forty years next preceding the approval of this Act, are hereby granted
HELD: The court allowed the reopening of the case since the case was filed within the 40year period imposed by the act. Joaquins group believes that the difference between the title ( BY VIRTUE OF JUDICIAL DECISIONS RENDERED and in section 1(by virtue of judicial proceedings instituted), is material. If the title is to be followed, the date November 13, 1922 should be the date used in reckoning the period (which is still within the 40-year period; counted from the date of the enactment of R.A. 931 which is June 20, 1953). But if the wordings of the title are to be followed, the date April 12, 1912 , which is the date the Director of lands instituted the reopening of the case, would render the petition invalid since it is already outside the 40-year period. The rule on statutory construction provides that laws should be construed liberally. The spirit or the intent of the law should be looked upon and should prevail over its letter. In this case, R.A. 931 clearly gives an opportunity to any person who has any interest in any parcel of land which has been declared as public land to present his claim within the time prescribed. This act is a piece of remedial legislation; its intent provides a mode of relief to landowners who, before the act had no legal means of perfecting titles. Therefore, the court cannot see an inconsistency between the title and its section. The title of the act is indisputably clear, as it expresses the very substance of the law itself. The constitutional jurisdiction that the subject of the statute must be expressed in the title, breathes the spirit of command because the constitution does not exact of Congress the obligation to read during its deliberations the entire text of the bill. Therefore, by the statute, the petition of Lutes to reopen the case, decision on which was rendered on Nov. 13, 1922, comes within the40-year period.
REPUBLIC ACT NO. 931 AN ACT TO AUTHORIZE THE FILING IN THE PROPER COURT, UNDER CERTAIN CONDITIONS, OF CERTAIN CLAIMS OF TITLE TO PARCELS OF LAND THAT HAVE BEEN DECLARED PUBLIC LAND, BY VIRTUE OF JUDICIAL DECISIONS RENDERED WITHIN THE FORTY YEARS NEXT PRECEDING THE APPROVAL OF THIS ACT Section 1. All persons claiming title to parcels of land that have been the object of cadastral proceedings, who at the time of the survey were in actual possession of the same, but for some justifiable reason had been unable to file their claim in the proper court during the time limit established by law, in case such parcels of land, on account of their failure to file such claims, have been, or are about to be declared land of the public domain, by virtue of judicial proceedings instituted within the forty years next preceding the approval of this Act, are hereby granted the right within five years after the date on which this Act shall take effect, to petition for a reopening of the judicial proceedings under the provisions of Act Numbered Twenty-two hundred and fifty-nine, as amended, only with respect to such of said parcels of land as have not been alienated, reserved, leased, granted, or otherwise provisionally or permanently disposed of by the Government, and the competent Court of First Instance, upon receiving such petition, shall notify the Government, through the Solicitor General, and if after hearing the parties, said court shall find that all conditions herein established have been complied with, and that all taxes, interests and penalties thereof have been paid from the time when land tax should have been collected until the day when the motion is presented, it shall order said judicial proceedings reopened as if no action has been taken on such parcels. Sec. 2. If any claimant entitled to the right granted under the preceding section has filed an application for homestead, free patent, sale or lease of the parcel of land in question under the provisions of Commonwealth Act Numbered One hundred forty-one, otherwise known as the Public Land Act, and the corresponding certificate of title to the same has not yet been issued to him by the Director of lands, the said claimant is hereby granted the option to either withdraw said application or exercise the right granted by this Act. Sec. 3. This Act shall take effect upon its approval. Approved: June 20, 1953

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27 SCRA 342 City of Baguio, ET AL. vs. PIO R. MARCOS, ET AL.G.R. No. L-26100 February 28, 1969Sanchez, J.

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