GR 33291; (March, 1931) (Digest)
G.R. No. 33291; March 21, 1931
THE MUNICIPALITY OF TAYTAY, applicant-appellant, vs. THE DIRECTOR OF LANDS, ET AL., opponents-appellees.
FACTS
The Municipality of Taytay applied for the registration of two parcels of land it claimed as its private property (bienes patrimoniales). It alleged possession for about 300 years, deriving income used for public purposes. The Director of Lands opposed, asserting the lands were part of the public domain. In a prior land registration case (G.R. No. 3663) involving the same lands, where the parish of Taytay was the applicant and the Municipality was an opponent, the Court of Land Registration (affirmed by the Supreme Court) had already denied registration, holding the lands belonged to the Crown of Spain (later the public domain of the U.S./Philippine Government). In the present case, the Municipality presented substantially the same evidence, including a 1656 Royal Decree of protection.
ISSUE
Whether the Municipality of Taytay has registrable title to the subject lands as its private property.
RULING
No. The Supreme Court affirmed the lower court’s judgment denying the Municipality’s application and decreeing the lands as public domain. The Court held that the doctrine of the “law of the case” applied, as all questions of fact and law had been conclusively settled in the prior case between the same parties over the same property. The evidence, including the 1656 decree, showed only that the officials and natives of Taytay were in possession and enjoyed the usufruct of the lands for common benefit, not that the Spanish government granted ownership to the municipality as a corporation. Following established doctrine (*City of Manila v. Insular Government; Municipality of Tacloban v. Director of Lands*), mere possession, leasing, and use of income for public purposes do not convert public lands into municipal private property absent a clear government grant of title. The Court modified the judgment to record the right of the inhabitants of Taytay to use and avail themselves of the products of the land.
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