G.R. No. L‑1935
November 6, 1906

FACTS
1. Clara Alfonso Buenaventura had possessed a 172.82‑sqm parcel on Corregidor Island (Calle Churruca‑Colon No. 2, San Jose) for more than thirty (30) years, as shown by her testimony, witnesses, and an expediente posesorio filed in the Cavite Registry of Property on 21 December 1901.
2. The land lay within the limits of Corregidor, which the President of the United States had declared a military reservation by Executive Order dated 16 April 1902.
3. On 15 January 1903 the Commanding General of the Division of the Philippines forced the petitioner to execute a lease of the same land.
4. The petition sought a decree declaring Buenaventura the absolute owner of the land and the building thereon.
5. The respondent (Commanding General) contended that, under Section 12 of the Act of July 1 1902 (U.S. Congress), all lands designated as military reservations were excluded from the legislative power of the Philippine Commission and therefore could not be transferred to private ownership by prescription or by the Commission’s statutes (Act No. 627, etc.).

ISSUE
Whether a parcel of land, not exceeding sixteen (16) hectares and situated within a U.S.‑declared military reservation, may be acquired by a native of the Philippines through ordinary prescription and the statutory mechanisms of the Philippine Commission, notwithstanding Section 12 of the 1902 congressional act that reserves such lands to the United States.

RULING
The Supreme Court affirmed the judgment of the Court of Land Registration.

1. Statutory Authority Section 14 of the Act of July 1 1902 expressly authorizes the Philippine Commission to issue patents without compensation to any native who actually occupied, before 13 August 1898, a public land not exceeding 16 hectares.

2. Applicability to Military Reservations Section 6 of Act No. 627 (enacted 9 February 1903) extends the provisions of §§ 38‑42 of Act No. 190 (Civil Procedure Code) to lands of ≤16 hectares within military reservations, thereby allowing acquisition by ordinary prescription of ten (10) years.

3. Prescriptive Title The petitioner’s possession for over thirty (30) years (including the requisite ten‑year period) satisfies the ordinary prescriptive period required under Section 6 of Act 627.

4. Effect of Section 12 The Court held that Section 12 of the 1902 congressional act merely reserves lands designated by the President for “military and other reservations” to U.S. control unless a specific congressional enactment expressly displaces that reservation. Acts 627, 496, and 809passed by the Philippine Commission with the concurrence of the U.S. Presidentlawfully created a limited exception for parcels not exceeding 16 hectares, and thus are not inconsistent with Section 12.

5. Resulting Title The expediente posesorio of 21 December 1901, the continuous possession, and the statutory allowances together justify the issuance of an absolute title in favor of Buenaventura.

Accordingly, the petition was granted, the lease executed under duress was declared void, and the land was ordered to be titled to Clara Alfonso Buenaventura.

Justice Arellano delivered the opinion; Justice Carson dissented.