G.R. No. L‑2746

FACTS
– On 23 June 1903 petitioner Mateo Cariño, through his attorney‑in‑fact Metcalf A. Clarke, filed a petition in the Court of Land Registration to be entered as owner of 146 ha of land in Baguio, Benguet.
– The Insular Government opposed, asserting the land formed part of the Baguio military reservation.
– The land‑registration court ruled for Cariño; the government appealed.
– The Court of First Instance tried the case de novo and dismissed the petition. Cariño brought a bill of exceptions to the Supreme Court.
– Cariño possessed only a 1901 possessory information under the Mortgage Law (Art. 394), which confers only the effects of mere possession.
– No documentary title from the Spanish or American government was produced. The land was agricultural and, under existing Spanish‑Era regulations (Royal Decree 25 June 1880; Royal Decree 13 Feb 1894), lands unadjusted by the deadline reverted to the State.

ISSUE
Whether a long‑standing, unperfected possession of a public agricultural land creates a presumption of grant (or an operative statute‑of‑limitations) against the State, thereby allowing the possessor to obtain title to the land.

RULING
– The Court held that the statute of limitations does not run against the State for public agricultural lands; consequently, no presumption of grant arises from mere possession, however long.
– The “presumption of grant” is not a rule of law but a factual inference that may be drawn only when surrounding circumstances support the existence of an actual grant. Here, the historical facts (failure of Spanish‑government land adjustments, the Igorot’s lack of legal integration, the petitioner’s own acknowledgment of only possession) disqualified such an inference.
– Citing earlier jurisprudence (Valenton v. Murciano; Cansino v. Valdez; Tiglao v. Insular Government) and U.S. cases (United States v. Chaves; Hays v. United States), the Court emphasized that a void or absent grant cannot be supplied by the passage of time.
– Accordingly, Cariño is not entitled to title under § 54(6) of Act 926 (Public Land Act), which does not apply to Benguet.
– The judgment of the Court of First Instance dismissing the petition is AFFIRMED, with costs against the appellant.

Decision concurring: Arellano, C.J., Torres, Carson, Tracey, and Mapa, JJ.