GR L 9845; (March, 1916) (Digest)
G.R. No. L-9845; March 28, 1916
J. C. RUYMANN and H. G. FARRIS, petitioners-appellants, vs. THE DIRECTOR OF LANDS, THE CITY OF MANILA, MARCIANO CABANDONG, LUIS CATOLOS, NAZARIO CRISOSTOMO, RUPERTO FAUSTO, ET AL., objectors-appellees.
(Consolidated Cases: Nos. 6321, 6762, 6850, 7543, and 7780, Court of Land Registration)
FACTS:
1. On July 26, 1904, the Governor-General issued Executive Order No. 33, creating the “Mariquina Reservation” in Rizal to protect the watershed of the Mariquina River, Manila’s water source. This was pursuant to Acts Nos. 627 and 648.
2. On October 1, 1909, the Court of Land Registration issued “Civil Reservation Order No. 81” for this reservation, which was duly published. The Order required all persons claiming private land within the reservation to file a petition for registration within six (6) months from the date of notice, which period expired on December 31, 1909.
3. On April 11, 1910, J.C. Ruymann and H.G. Farris filed a petition (Case No. 6321) to register 3,043 hectares within the reservation.
4. Subsequently, Ruymann and Farris filed two amended petitions (November 12, 1910, and October 20, 1911) seeking to register additional lands, expanding their claim to 16,648 hectares.
5. Other claimantsMarciano Cabandong, Luis Catolos, Nazario Crisostomo, and Ruperto Faustofiled their respective petitions for registration (Cases Nos. 6762, 6850, 7543, and 7780) on various dates from September 1910 to November 1911.
6. The Director of Lands, the City of Manila, and the other claimants opposed the petitions. A primary ground for opposition was that all amended petitions by Ruymann and Farris (for additional lands) and all petitions by the other claimants were filed after the six-month statutory deadline.
7. The Court of Land Registration denied all petitions. Ruymann and Farris, as well as the other claimants, appealed.
ISSUE:
1. May a petition for registration filed within the statutory period be amended after the lapse of that period to include additional lands, thereby vesting the court with jurisdiction over such new lands?
2. Does the court acquire jurisdiction to register land when the petition is filed after the expiration of the period allowed by law for filing such petitions?
RULING:
2. On the second issue: NO. The filing period is jurisdictional. Section 4 of Act No. 627 provides that claims not presented within six months “shall be forever barred, and the lands… shall be deemed to be public and not private property.” Therefore, the court has no jurisdiction to entertain petitions filed after the deadline. All petitions filed by Marciano Cabandong, Luis Catolos, Nazario Crisostomo, and Ruperto Fausto were correctly denied for being filed out of time.
Regarding the Merits of Ruymann and Farris’s Original Claim:
The Supreme Court examined the title of their predecessor-in-interest, Robert Wilson. The evidence established that Wilson validly acquired, via a Spanish royal title, a hacienda with an area of 585 quinones, 3 balitas, and 6 loanes. The Court found that Ruymann and Farris had sufficiently proven their title to this land, which was equivalent to the 3,043 hectares described in their original (April 11, 1910) petition. Since this original petition was filed within the six-month period, they are entitled to its registration.
DISPOSITIVE PORTION:
The decision of the lower court was AFFIRMED IN PART and MODIFIED IN PART.
1. The denial of registration in Cases Nos. 6762, 6850, 7543, and 7780 (the petitions of Cabandong, Catolos, Crisostomo, and Fausto) is AFFIRMED.
2. The denial of registration for the lands claimed in the amended petitions of Ruymann and Farris is AFFIRMED.
3. A judgment is ORDERED for the registration in favor of J.C. Ruymann and H.G. Farris of the parcel of land containing 3,043 hectares, 85 ares, and 28 centares, as described in their original petition filed on April 11, 1910. No costs.
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