G.R. No. 35776 ; August 21, 1931
THE DIRECTOR OF LANDS, in behalf of the Government of the Philippine Islands, petitioner, vs. BUENAVENTURA OCAMPO, Judge acting in vacation in the Court of First Instance of Nueva Ecija, and AMBROSIO MANUEL, respondents.

FACTS

In a 1922 cadastral proceeding, Lot No. 1368 was declared public land. Later, Act No. 3672 was passed, allowing claims to such lands within one year from the Act’s “promulgation.” The Governor-General initially issued Proclamation No. 299 on February 28, 1930, stating the Act was approved by the U.S. President on February 7, 1930. This was corrected by Proclamation No. 307 on March 26, 1930, stating the actual approval date was February 17, 1930. On March 12, 1931, respondent Ambrosio Manuel filed a motion to reopen the cadastral case and claim the lot. The trial judge granted the motion and adjudicated the lot to Manuel. The Director of Lands filed a certiorari petition, arguing Manuel’s motion was filed beyond the one-year period if counted from the first proclamation.

ISSUE

From what date should the one-year period for filing claims under Act No. 3672 be computed?

RULING

The one-year period should be computed from March 26, 1930, the date of Proclamation No. 307. This second proclamation substantially amended the first by correcting the actual date of the U.S. President’s approval of the Act, which was the basis for determining the Act’s effectivity. Therefore, Proclamation No. 307 abrogated Proclamation No. 299. Since Manuel filed his motion on March 12, 1931, it was within the one-year period from March 26, 1930. The trial judge’s orders were valid and within jurisdiction. The petition for certiorari is denied.

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