G.R. No. L-8536; April 28, 1956
The Intestate of Fausto Bayot, represented by CELESTE BAYOT, Judicial Administratrix, applicant-appellee, vs. THE DIRECTOR OF LANDS, oppositor-appellant.

FACTS

The intestate estate of Fausto Bayot, represented by Celeste Bayot, filed an application for registration of a parcel of land in Masbate containing 11,354.093 square meters (or 1,135 hectares), with an alternative prayer for the benefit of Chapter VIII of Commonwealth Act No. 141 . The application claimed peaceful possession under claim of ownership since time immemorial. The Director of Lands opposed, asserting the land was part of the public domain. The Court of First Instance ordered the registration of the entire land. The evidence showed that on November 10, 1888, Natividad Perez was granted a Spanish title to a parcel of land with an area of 151 hectares, 47 ares and 80 centares. Lucas Bayot bought this land on November 20, 1920, and sold it to Fausto Bayot on November 30, 1920. Fausto Bayot subsequently increased the declared area in tax declarations, first to 1,085 hectares and later to 1,135 hectares. Witness testimony indicated Fausto Bayot used the land for cattle raising from around 1920, constructing improvements and enclosing it with barbed wire, until the cattle were lost during the Japanese occupation. Vicente Oliva, an oppositor, testified he applied for a pasture permit for a portion of the land in 1948.

ISSUE

Whether the applicant is entitled to register the entire land applied for (1,135 hectares) despite the Spanish title of its predecessor-in-interest covering only 151 hectares, 47 ares and 80 centares.

RULING

The Supreme Court modified the lower court’s decision. The applicant is entitled to register only the area stated in the original Spanish title (151 hectares, 47 ares and 80 centares), not the entire 1,135 hectares applied for. The general rule that boundaries prevail over area applies only when the boundaries are sufficiently certain to clearly segregate the land. Here, the northern boundary “Monte Layat” (Mt. Layat) was vague and indefinite, failing to accurately segregate the land. The enormous disparity in area (over seven times the original) was due to this indefiniteness. Furthermore, Spanish Royal Decrees limited acquisitions of public land to a maximum of 1,000 hectares, lands were sold by unit of measure (price per hectare), and only a 5% error in measurement was permitted. The land did not fit these requirements. The alternative claim of possession under Commonwealth Act No. 141 also failed, as the evidence showed possession only from around 1910, not from July 26, 1894, as required.