G.R. No. 40940; September 5, 1934
CRISTOBAL MARCOS, applicant-appellant, vs. THE DIRECTOR OF LANDS, ET AL., oppositor-appellees.

FACTS

Cristobal Marcos applied for confirmation and registration of title over a parcel of land in Masbate. He derived his claim from a series of sales originating from a Spanish-era title of adjustment (composición con el Estado) issued in 1889 to Aldecoa y Cia., covering 898 hectares, 18 ares, and 50 centares. The land described in Marcos’s application, however, had an area of approximately 1,400 hectares according to his tax declaration and plan, representing a significant excess over the area in the original Spanish title. The Director of Lands and the Director of Forestry opposed the application, asserting that portions of the land were public domain, including a mangrove swamp and forest land. The trial court ordered registration only of the area corresponding to the original Spanish title, excluding the excess and the forested portions.

ISSUE

Whether the applicant is entitled to the registration of the entire area of approximately 1,400 hectares described in his application, including the excess over the area specified in the original Spanish title of adjustment.

RULING

No. The Supreme Court affirmed the trial court’s decision, limiting registration to the area specified in the original Spanish title. The Court held that where a Spanish title states a specific area and the boundaries are not all natural (some being public land), the registrable area cannot exceed that stated in the title. The applicant failed to conclusively prove that the excess land had been acquired by possession for the required period and in the manner prescribed by the Public Land Act (Act No. 2874). His possession of the excess land, which began only in 1927, did not meet the requirement of possession since 1894 under the law. The opposition of the Director of Forestry regarding the mangrove swamp and forestal reservation was also properly sustained.

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