GR L 7997; (January, 1915) (Digest)
G.R. No. L-7997; January 25, 1915
Case Title: Municipality of Hagonoy, petitioner-appellant, vs. The Roman Catholic Archbishop of Manila, respondent-appellant.
FACTS:
The Municipality of Hagonoy filed an application for the adjudication and registration in its favor of several parcels of land located within the municipality. The Roman Catholic Archbishop of Manila opposed the registration of the third and fifth parcels, claiming ownership. The Director of Lands, on behalf of the Philippine Government, opposed the registration of the third, fifth, sixth, seventh, ninth, tenth, eleventh, twelfth, thirteenth, fourteenth, and fifteenth parcels. The trial court denied the registration of the sixth and seventh parcels, siding with the Director of Lands, and also denied the registration of the third parcel, ruling it was a municipal plaza and therefore not subject to registration. Both the Municipality of Hagonoy and the Roman Catholic Archbishop of Manila appealed the decision.
ISSUE:
1. Whether the Municipality of Hagonoy is entitled to the registration of parcels of land (specifically parcels 6 and 7) based on its possession and collection of rentals from occupants.
2. Whether the Roman Catholic Archbishop of Manila has a superior claim of ownership over the third and fifth parcels.
RULING:
The Supreme Court affirmed the judgment of the trial court.
1. Regarding parcels 6 and 7: The Court held that the Municipality of Hagonoy is not entitled to registration. Mere possession and the collection of rents from private occupants, without proof that the land was used for a recognized public purpose based on a public necessity (such as for public buildings), is insufficient to presume a grant from the state. The municipality failed to prove an express grant or that the land was used for purposes traditionally recognized by the former government as a basis for municipal grants. Following Municipality of Tacloban vs. Director of Lands, the act of collecting rentals at most makes the municipality a usufructuary, not an owner with registrable title.
2. Regarding the claims of the Roman Catholic Archbishop: The Court found the trial judge’s findings of fact to be fully sustained by the evidence. The evidence did not support the claim that the municipality’s long-term use of parcel 5 (as a market place for over 50 years) and parcel 3 (used as a public place) was subject to the control or consent of the church. Therefore, the church’s claim of ownership was properly rejected.
The costs of the appeal were assessed against the appellants.
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