GR L 14029; (October, 1919) (Digest)
G.R. No. L-14029; October 15, 1919
MARIA BALTAZAR, ET AL., applicants-appellants, vs. THE INSULAR GOVERNMENT, ET AL., objectors-appellees.
FACTS:
The heirs of Lucino Almeida applied for the registration of two parcels of land in Balaoan, La Union, totaling 815 hectares. They based their claim on a public sale document (Exhibits B and D) dated June 9, 1895, covering about 526 hectares, and a possessory information (Exhibit C) inscribed on December 12, 1896. The Insular Government opposed, asserting that portions of the land were forest land, supported by a forest ranger’s testimony that 122 hectares were forest or non-commercial woodland. Ten private individuals also opposed, claiming ownership through prescription. The Court of First Instance denied the application, finding insufficient proof of ownership over the entire tract and noting the inclusion of forest land. The court suggested that the applicants could amend their plan and petition for registration of the portion covered by their title deeds. The applicants appealed.
ISSUE:
1. Whether the trial court erred in not adjudicating the claims of the private opponents.
3. Whether the trial court erred in denying the application, particularly regarding the land covered by Exhibit B.
RULING:
1. No error regarding the private opponents’ claims. The trial court correctly limited itself to determining the applicants’ entitlement to registration. The private opponents, not being applicants themselves, had no right to a definitive settlement of their claims in this proceeding.
2. No error regarding the possessory information. The possessory information, issued on December 12, 1896, was invalid under the Maura Law (Royal Decree of February 13, 1894), which required possessory informations to be perfected by April 17, 1895. Since Almeida acquired the land on June 9, 1895, and the information was issued after the deadline, it could not serve as prima facie evidence of possession or ownership.
3. No error in denying the application. The trial court correctly found that the applicants could be entitled to register the portion covered by Exhibit B, but the boundaries were vague and indefinite. The denial was without prejudice, allowing the applicants to amend their petition and submit a proper plan to identify the land with reasonable accuracy.
The Supreme Court affirmed the judgment of the trial court, with costs against the appellants.