GR L 3279; (March, 1908) (Digest)
FACTS:
On November 11, 1904, The City of Manila, through its attorney, filed a petition in the Court of Land Registration for the registration of a parcel of land in Paco, Manila, described by metes and bounds. The City of Manila alleged that it was the absolute owner of the land, having obtained title as the successor to all the rights and actions of the old city of Manila (ayuntamiento de Manila), to which the property formerly belonged. It claimed the land was unoccupied and free from liens.
The Insular Government opposed the registration, asserting that the land in question was the property of the Government of the United States under its control. The opposition of another party, Geronimo Morales, for a portion of the land, was also noted. The case record delves into various Spanish royal decrees and orders concerning legua comunal (communal lands) granted to pueblos (towns), which consistently required specific designation, survey, and marking by public authorities before a pueblo could acquire a vested right or title. American jurisprudence on lands acquired from Spain likewise held that until lands were definitely assigned and measured, the right of the pueblo was imperfect, and the fee remained with the sovereign.
ISSUE:
Did the City of Manila prove its ownership over the subject land, demonstrating a vested right or title acquired through a grant from the former sovereign (Spain) or by virtue of present law, to warrant its registration?
RULING:
The Supreme Court reversed the judgment of the lower court. The Court ruled that The City of Manila failed to present proof showing that the land in question had been specifically granted to it by the former sovereign in these Islands, nor did it show entitlement to said lands by virtue of any law of the present sovereign. Under Spanish law, it was necessary for the proper authorities to particularly designate and assign land to towns or pueblos before a vested right or title to the use thereof could arise. Lands not actually allotted to settlers remained the property of the King, and the fee of lands within the limits of pueblos continued to remain in the sovereign, not in the pueblo as a corporate body. Since the petitioner failed to provide such evidence of a specific grant, the Court of Land Registration was not empowered to grant the registration of said lands in its favor.
