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Ramos v. Lands

Ramos v. Director of Lands, G.R. No. L-13298, November 19, 1918

G.R. No. L-13298November 19, 1918Ponente: MALCOLM, J.
  • Civil Law
  • land registration
  • possessory information title
  • Act No. 926
  • public land law
  • bona fide claim of ownership
  • open continuous exclusive notorious possession
  • Royal Decree of February 13, 1894
  • Maura Law
  • forest land vs. agricultural land
  • government grant conclusive presumption
  • Philippine Bill (Act of Congress of July 1, 1902)

Read the full decision

I. Facts of the Case

Cornelio Ramos bought in February 1907 Parcel No. 1, which was within the possessory information title earlier obtained by Restituto Romero y Ponce (registered February 8, 1896 under the Royal Decree of February 13, 1894). Ramos sought registration of the larger portion of Parcel No. 1, but the Court of First Instance of Nueva Ecija excluded it after opposition that Ramos allegedly lacked a good title and that the land was forest land.

  1. 1882

    Restituto Romero y Ponce apparently took possession of a considerable tract of land in San Jose, Nueva Ecija.

  2. February 8, 1896

    Using the Royal Decree of February 13, 1894, Romero obtained and had registered a possessory information title over the land.

  3. February 1907

    Parcel No. 1 within Romero’s possessory information title was sold to Cornelio Ramos and his wife Ambrosia Salamanca.

  4. Ramos instituted proceedings to register his title; the Director of Lands opposed for lack of good title from the Spanish government, and the Director of Forestry opposed on the ground that the first parcel was forest land.

  5. The Court of First Instance of Nueva Ecija agreed with the objectors and excluded Parcel No. 1 from registration.

  6. Ramos appealed to the Supreme Court, arguing that he and his predecessor in interest had acquired registrable title under subsection 6 of section 54 of Act No. 926 (as amended by Act No. 1908), with reference to the Philippine Bill and the Royal Decree of February 13, 1894.

  7. November 19, 1918

    The Supreme Court reversed the trial court and ordered registration of the entire tract in Parcel No. 1 as described in plan Exhibit A.

II. Issues

1
Civil Law

Whether or not the petitioner and appellant proved a title to the entire tract of land for which he asked registration under subsection 6 of section 54 of Act No. 926, as amended by Act No. 1908, with reference to the Philippine Bill and the Royal Decree of February 13, 1894.

III. Ruling

Issue 1Civil Law

Whether or not the petitioner and appellant proved a title to the entire tract of land for which he asked registration under subsection 6 of section 54 of Act No. 926, as amended by Act No. 1908, with reference to the Philippine Bill and the Royal Decree of February 13, 1894.

Yes

The Supreme Court held that Ramos and his predecessor in interest proved title to the entire tract sought for registration under subsection 6 of section 54 of Act No. 926 (as amended by Act No. 1908), and ordered the registration of the entire tract in Parcel No. 1 as described in plan Exhibit A.

How the Court reasoned

  1. The Court focused on subsection 6 of section 54 of Act No. 926 (as amended by Act No. 1908), which provides a conclusive presumption of compliance with essential conditions for a government grant upon proof of qualifying possession under a bona fide claim of ownership.
  2. Although the Solicitor-General argued that the land should not be protected under the Royal Decree of February 13, 1894 because it might have been forest land and not cultivated for the required period, the Court stated it was unnecessary to definitively resolve that contention.
  3. The Court explained that it was sufficient for the case that the predecessor in interest had held the tract under color of title, which supported Ramos’s claim for registration under the statutory possession requirements.
  4. Applying subsection 6 of section 54, the Court concluded that Ramos had proved the necessary entitlement for a certificate of title to the entire tract sought, not merely a portion.
“We hold that the petitioner and appellant has proved a title to the entire tract of land for which he asked registration, under the provisions of subsection 6, of section 54, of Act No. 926, as amended by Act No. 1908, with reference to the Philippine Bill and the Royal Decree of February 13, 1894, and his possessory information.”

Rule applied

Subsection 6 of section 54 of Act No. 926 (Public Land Law), as amended by Act No. 1908; Act of Congress of July 1, 1902 (Philippine Bill); Royal Decree of February 13, 1894

Doctrines

1

Under subsection 6 of section 54 of Act No. 926 (as amended by Act No. 1908), persons (and their predecessors in interest) who have been in open, continuous, exclusive, and notorious possession and occupation of agricultural public lands under a bona fide claim of ownership (except as against the Government) for the statutory period are conclusively presumed to have performed all essential conditions for a government grant and are entitled to a certificate of title.

Final Disposition

Judgment is reversed and the lower court shall register in the name of the applicant the entire tract in parcel No. 1, as described in plan Exhibit A, without special finding as to costs.

Notes

The Court indicated that it did not need to finally decide the specific Maura Law contention regarding whether the land was forestal and whether cultivation requirements for Maura Law protection were met, because entitlement could be sustained under the statutory possession rule in Act No. 926 as amended.