G.R. No. 37454; June 23, 1934
JOSE L. DE LEON and NATIVIDAD JOVEN, applicants-appellees, vs. THE DIRECTOR OF LANDS, ET AL., oppositors-appellants.

FACTS

The spouses Jose L. de Leon and Natividad Joven applied for registration of a 61-hectare parcel of land in Tarlac, claiming ownership through a Spanish Titulo de Composicion dated 1890 covering only 13 hectares. They alleged possession by themselves and their predecessors for over 50 years. The Director of Lands and seven homesteaders, who were occupying portions of the land under homestead applications, opposed the registration, claiming the land was part of the public domain. The trial court granted the application in full and issued an injunction against the homesteaders without notice or hearing. The homesteaders and the Director of Lands appealed.

ISSUE

Whether the applicants have a valid and registrable title to the entire 61-hectare land, or only to the area originally covered by the Spanish title.

RULING

The Supreme Court reversed the trial court’s decision. The Spanish composition title (Exhibit E) was valid only for the original area of 13 hectares, 96 ares and 50 centiares. The Junta Provincial that issued it had no authority to grant titles exceeding 30 hectares. The applicants failed to prove continuous, peaceful, and adverse possession of the excess area of about 47 hectares. That excess portion, occupied by the homesteaders, is declared public land. The injunction issued against the homesteaders was vacated as improvidently granted. The Court adjudicated only the 13-hectare area to the spouses De Leon and remanded the case for further proceedings.

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