GR L 7922; (August, 1915) (Digest)
G.R. No. L-7922; August 27, 1915
THE MUNICIPALITY OF LAOAG, petitioner-appellant, vs. THE DIRECTOR OF LANDS, ET AL., objectors-appellees.
FACTS:
On August 31, 1908, the Municipality of Laoag filed a petition in the Court of Land Registration seeking the registration under the Torrens system of three parcels of land. The Municipality claimed ownership based on its immemorial occupation of the properties. The Director of Lands and other appellees opposed the registration. After trial, the auxiliary judge of the Court of Land Registration denied the petition, finding that the Municipality failed to prove that the lands were granted to it by the state as patrimonial property or that they were used for proper municipal purposes. The Municipality appealed the decision.
ISSUE:
Whether the Municipality of Laoag has sufficiently established its ownership over the subject parcels of land to entitle it to registration under the Torrens system.
RULING:
No. The Supreme Court affirmed the decision of the lower court. The Court held that the evidence presented by the Municipality was insufficient to prove ownership in fee simple. Mere collection of rents from occupants and immemorial occupation, without proof of an express grant from the government or use of the land for proper municipal purposes (such as the erection of buildings for public service), does not establish municipal ownership. The facts of the case were found to be analogous to and governed by the precedent set in Municipality of Tacloban vs. The Director of Lands (18 Phil. Rep., 201), which requires an express grant from the state for a municipality to claim land as part of its patrimony. Consequently, the Municipality was not entitled to registration. The appeal, being a question of fact, was resolved by affirming the lower court’s findings. The judgment was affirmed with costs.
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