GR L 8243; (December, 1915) (Digest)
G.R. No. L-8243, December 24, 1915
THE GOVERNMENT OF THE PHILIPPINE ISLANDS, petitioner-appellee, vs. THE MUNICIPALITY OF BINALONAN, objector-appellee, and THE ROMAN CATHOLIC BISHOP OF NUEVA SEGOVIA, objector-appellant.
FACTS:
The Director of Lands instituted compulsory registration proceedings under Section 61 of Act No. 926 (the Public Land Act) for all private property within a prescribed area in the municipality of Binalonan, Pangasinan. Among the private claimants were the Roman Catholic Bishop of Nueva Segovia and the Municipality of Binalonan, both claiming ownership of two specific parcels of land. The trial court awarded the lots to the Municipality. The Bishop appealed, contesting both the award on the merits and the very authority to conduct compulsory registration of private lands under Section 61 of Act No. 926 .
ISSUE:
1. Whether Section 61 of Act No. 926 authorizes the institution of compulsory registration proceedings against private owners, or if it applies only to public lands.
2. Whether compulsory registration statutes are constitutional.
3. On the merits, whether the appellant Bishop has a superior right to the disputed lots over the Municipality.
RULING:
1. On the Scope of Section 61, Act No. 926 : The Supreme Court held that Section 61 of Act No. 926 applies to all lands in the Philippine Islands, whether public or private. The Court rejected arguments based on the title of the Act or the subsequent enactment of the Cadastral Act ( Act No. 2259 ) as limiting Section 61’s scope. The phrase “any land in the Philippine Islands” is unambiguous and inclusive. The reference to holders who “shall not have voluntarily come in under the provisions of this chapter or the Land Registration Act” confirms its application to private lands, as the Land Registration Act ( Act No. 496 ) provided for voluntary registration of private titles. The Cadastral Act was enacted not to confer new jurisdiction but to establish a more detailed and comprehensive procedure (e.g., for survey costs and notice) for proceedings already authorized under Section 61.
2. On Constitutionality: The Court affirmed that compulsory registration statutes are constitutional, citing its prior ruling in Jose vs. Commander of Philippine Squadron.
3. On the Merits: The Supreme Court affirmed the trial court’s judgment awarding the lots to the Municipality of Binalonan. The evidence established that both lots were bounded by public streets and were never within the church’s walled property. One lot had consistently served as a public plaza, and the other had been the site of a public school since at least 1877. The municipal government, not the church, administered the properties. Occasional use of portions of the land for religious processions was insufficient to overcome the evidence of municipal ownership and possession.
Judgment affirmed, with costs against the appellant.
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