G.R. No. L-34602 May 31, 1979
THE DIRECTOR OF LANDS and DIRECTOR OF FORESTRY, petitioners, vs. LILIA A. ABAIRO, CELSO ABAIRO and THE COURT OF FIRST INSTANCE OF ISABELA, respondents.

FACTS

On March 1, 1971, respondent Lilia Abairo filed an application for judicial confirmation of title over a 573-square-meter parcel of land in Isabela under the Land Registration Act. She claimed open, public, peaceful, and uninterrupted possession in the concept of an owner by herself and her predecessors-in-interest since time immemorial. At the initial hearing, the assistant provincial fiscal, representing the Bureau of Lands and Bureau of Forestry, withdrew the government’s opposition. He cited a new law extending the filing period for registration petitions and submitted reports from both bureaus indicating no opposition. Consequently, the trial court issued an order of general default and proceeded to receive evidence.
The respondent Court of First Instance of Isabela rendered a decision on September 27, 1971, confirming the ownership of Lilia and Celso Abairo. The court found that the land was originally owned by Pablo Rivera since 1912, subsequently sold to Inocencia Accad in 1939, and then to Lilia Abairo in 1969. It ruled that the applicants and their predecessors had possessed the land openly, publicly, peacefully, and uninterruptedly in the concept of owners, and that the land was free from liens.

ISSUE

Whether or not the trial court had jurisdiction to entertain the application for registration filed on March 1, 1971, which was after the expiry date of December 31, 1968, set by Republic Act No. 2061, but before the effectivity of Republic Act No. 6236 on June 19, 1971, which extended the filing period.

RULING

The Supreme Court affirmed the lower court’s decision, holding that it had jurisdiction. The legal logic centers on the retroactive application and inherent purpose of the amendatory laws. Republic Act No. 6236, enacted on June 19, 1971, amended Section 47 of Commonwealth Act No. 141 by extending the deadline for filing applications for judicial confirmation of imperfect titles to December 31, 1976. Crucially, the amended section contained a proviso stating it “shall not be construed as prohibiting any of said persons from acting under this chapter at any time prior to the period fixed by the President.” No such period had been fixed by the President.
The Court reasoned that this proviso, present in all amendments including R.A. No. 2061, allowed applications to be filed at any time before the final deadline. Therefore, an application filed during the intervening period between the lapse of the old deadline (January 1, 1969) and the effectivity of the new law (June 19, 1971) was considered timely filed. The extension granted by R.A. No. 6236 retroactively covered applications filed after January 1, 1969. Furthermore, the Court emphasized the legislative intent to provide qualified applicants full opportunity to own disposable public land, a policy reflected in subsequent extensions. Dismissing the application over a small 573-square-meter lot, especially after the government agencies withdrew their opposition, would be overly technical and oppressive. Hence, the trial court validly acquired jurisdiction.