Baltazar vs The Insular Government, et al.

GR No. L-14029. October 15, 1919

Facts:
The heirs of the deceased Lucino Almeida applied to the CFI of La Union for the
registration in their name of two parcels of land. The applicants relied on the documents of a
public sale of two parcels of land with a chain of title; certified copy of possessory information of
the land in question, secured by Almeida and inscribed in the registry of property on December
12, 1896; and oral testimony was also presented.
The Attorney-General opposed the registration on the ground that it includes forest lands.
Ten private individuals also opposed the registration because they acquired title through
prescription.
The application was denied; without prejudice.

Issue:
Whether or not the possessory information presented by the applicant should be
considered as title to the lands.

Ruling:
No.
The facts involved three important dates. The time within which advantage could be taken
of the Maura Law expired on April 17, 1895. Almeida obtained dominion over 526 hectares of
land on June 9, 1895. The possessory information for 815 hectares was issued to Almeida on
December 14, 1896. Almeida was thus not in possession until after the expiration of the period
specified by the Maura Law for the issuance of possessory titles and his possessory information
was of even a later date and made to cover a large excess of land. Under these conditions, the
possessory information could not even furnish, as in other cases, prima facie evidence of the fact
that at the time of the execution the claimant was in possession, which it would be possible to
convert into ownership by uninterrupted possession for the statutory period.
The trial court committed no error in denying registration and in leaving it possible for the
applicants to reinstate their cause.
Director of Lands vs Datu
GR No. L-57573. July 5, 1982

Facts:
The respondent spouses filed an application for registration of a parcel of land. The
Director of Lands opposed the application alleging that the land had already been declared public
land in a cadastral proceeding.
Datu testified that he possessed the lot openly, adversely, notoriously and in the concept
of owner since 1950 when it was sold to him by Cipriano Peaflor, who allegedly possessed the
same since 1938, but the deed of sale was executed only on May 6, 1974, when consent of the
Commission on National Irrigation was secured; and that he converted the land from cogon land
to sugarcane land, but he did not specify when. There was no allegation as to how Peaflor
acquired the said land, neither did he (Peaflor) testified. Datu presented as evidence tax
declarations in his name for years 1972 and 1974, and as witness his cousin who testified as to
his possession of the land.
The trial court, later affirmed by the Court of Appeals, ordered the registration of the land
in favor of respondent spouses on the theory that they and their predecessor, Peaflor, had
possessed the land for more than thirty years and that they had imperfect title to it which could
be judicially confirmed pursuant to Sec 48(b) of the Public Land Laws as amended.
The Director of Lands appealed contending that the Datu spouses had not sufficiently
established their claim for 30 years possession.

Issue:
Whether or not juris et de jure presumption that the lot claimed by the applicant had
ceased to be a public land and had become private property.

Ruling:
No.
The Supreme Court held that the Datu spouses failed to prove possession for 30 years by
sufficient evidence and that the juris et de jure presumption that the lot claimed by the applicant
had ceased to be a public land and had become private property cannot be applied to this case.
Considering that the applicant failed to prove that acts of ownership and cultivation were
performed by their predecessor-in-interest; that they declared the land for taxation only in 1972;
that they did not prove when they or their tenant started cultivating the land; and that the
investigator of the Bureau of Lands reported that the land was cogon land. It cannot be said with
certitude that the applicant and their predecessor had possessed the lot under claim of
ownership for 30 years preceding the filing of their application. On the basis of applicants
insubstantial evidence, it cannot justifiably be concluded that they had performed all the
conditions essential to a government grant of a portion of public domain. The Court cannot apply
juris et de jure presumption that the lot claimed by the applicant had ceased to be a public land
and had become private property. The record does not substantiate an implied grant from the
state arising from more than 30 years possession under claim of ownership.