G.R. No. 43361; August 21, 1937
THE PROVINCE OF CAMARINES SUR, applicant, vs. THE DIRECTOR OF LANDS, oppositor-appellee. CIRIACO CHUNACO and JOSE ARAMBURO, oppositors and appellants.

FACTS

The Province of Camarines Sur filed an application for registration of several parcels of land comprising its agricultural school site. The Director of Lands opposed, claiming the lands were public. Oppositors Ciriaco Chunaco and Jose Aramburo also opposed, specifically claiming ownership of Lot No. 3, which Chunaco had purchased from Aramburo. The trial court denied the province’s application, overruled the oppositors’ claim, and declared Lot No. 3 public land, reserved for the agricultural school site. Chunaco and Aramburo appealed.

ISSUE

Whether the trial court erred in declaring Lot No. 3 public land instead of adjudicating and registering it in the name of oppositor Ciriaco Chunaco.

RULING

No, the trial court did not err. The Supreme Court affirmed the decision declaring Lot No. 3 public land. The appellants failed to prove a registrable title. They could not invoke possessory information title under Spanish laws as their predecessors never instituted such proceedings, causing the land to revert to the state. Their claim of ownership based on continuous, open, and adverse possession since 1874 also failed. The evidence showed the land was used only for seasonal pasturing and casual cultivation, which constitutes mere possession or tolerance, not the possession under claim of ownership required by the Public Land Acts to acquire title. Furthermore, tax declarations and an offer to purchase by the provincial governor do not constitute proof of ownership or create estoppel against the Government.

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