GR 33291; (March, 1931) (CRITIQUE)
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THE AI-ASSISTED CRITIQUE
The court’s reliance on the law of the case doctrine is sound, as the municipality’s claim to ownership over the same parcels was already adjudicated in a prior proceeding where it was an opponent. The municipality presented substantially the same evidence, primarily ancient documents and proof of collecting rents, which the court correctly deemed insufficient to establish title. The prior holding that mere possession and usufruct do not equate to ownership under Spanish law principles is binding, preventing relitigation of the core issue of ownership. This application of preclusion promotes judicial economy and finality, especially given the identical factual matrix and parties in interest.

The decision correctly distinguishes between administrative possession for communal benefit and patrimonial ownership. The 1656 writ of protection merely confirmed the town’s usufructuary rights over the fishery and lands for its inhabitants’ common use, not a sovereign grant transferring dominium. Under the prevailing Spanish law doctrine, reiterated in City of Manila vs. Insular Government, municipalities held no inherent right to communal lands; ultimate title remained with the Crown, later passing to the state. The municipality’s acts of leasing and collecting rents, while lengthy, constituted administrative control over public domain, not evidence of a patrimonial estate. The court properly rejected the argument for a presumption of grant, as such a presumption requires clearer evidence of a sovereign act of alienation, absent here.

However, the judgment’s modification to record the inhabitants’ usufructuary rights is a critical, albeit limited, recognition of customary use. While denying titular registration, the court preserved the community’s historical and beneficial interest, preventing complete dispossession. This balances the strict public domain doctrine with equitable considerations, acknowledging that while the state holds ultimate title, long-standing communal use creates a registrable right short of ownership. The elimination of reimbursement for survey costs further underscores that the municipality was acting in a governmental, not proprietary, capacity in seeking registration, aligning with the finding that the land is inalienable public land.