CARIO vs THE INSULAR GOVERNMENT, G.R. No.

L-2746
December 6, 1906
MATEO CARIO vs THE INSULAR GOVERNMENT

G.R. No. L-2746 December 6, 1906

FACTS: On June 23, 1903, Mateo Cario went to the Court of Land Registration to petition his inscription as the owner of
a 146 hectare land hes been possessing in the then municipality of Baguio. Mateo only presented possessory information
and no other documentation. The State opposed the petition averring that the land is part of the US military reservation.
The CLR ruled in favor of Mateo. The State appealed. Mateo lost. Mateo averred that a grant should be given to him by
reason of immemorial use and occupation as in the previous case Cansino vs Valdez & Tiglao vs Government.

ISSUE: Whether or not Mateo is the rightful owner of the land by virtue of his possession of it for some time.

HELD: No. The statute of limitations did not run against the government. The government is still the absolute owner of the
land (regalian doctrine). Further, Mateos possession of the land has not been of such a character as to require the
presumption of a grant. No one has lived upon it for many years. It was never used for anything but pasturage of animals,
except insignificant portions thereof, and since the insurrection against Spain it has apparently not been used by the
petitioner for any purpose.

While the State has always recognized the right of the occupant to a deed if he proves a possession for a sufficient length
of time, yet it has always insisted that he must make that proof before the proper administrative officers, and obtain from
them his deed, and until he did the State remained the absolute owner.

Cruz vs DENR, G.R. No. 135385, December 6, 2000

Isagani Cruz v. Dept. of Energy and Natural Resources,
G.R. No. 135385, December 6, 2000

FACTS: Cruz, a noted constitutionalist, assailed the validity of the RA 8371 or the Indigenous Peoples Rights Act on the
ground that the law amount to an unlawful deprivation of the States ownership over lands of the public domain as well as
minerals and other natural resources therein, in violation of the regalian doctrine embodied in Section 2, Article XII of the
Constitution. The IPRA law basically enumerates the rights of the indigenous peoples over ancestral domains which may
include natural resources. Cruz et al content that, by providing for an all-encompassing definition of ancestral domains
and ancestral lands which might even include private lands found within said areas, Sections 3(a) and 3(b) of said law
violate the rights of private landowners.

ISSUE: Whether or not the IPRA law is unconstitutional.

HELD: The SC deliberated upon the matter. After deliberation they voted and reached a 7-7 vote. They deliberated again
and the same result transpired. Since there was no majority vote, Cruzs petition was dismissed and the IPRA law was
sustained. Hence, ancestral domains may include natural resources somehow against the regalian doctrine.
CASE DIGEST: Krivenko vs. The Register of Deeds, City of
Manila
G.R. No. L-360 November 15, 1947

ALEXANDER A. KRIVENKO, petitioner-appelant, vs. THE REGISTER OF DEEDS, CITY OF MANILA, respondent and appellee.

FACTS:

Alexander Krivenko, an alien, bought a residential lot in December of 1941. The registration was interrupted by war. In
1945, he sought to accomplish the registration but was denied by the register of deed on ground that, being an alien, he
cannot acquire land within the jurisdiction. Krivenko appealed to the Court.

ISSUES:

2. Whether or not the prohibitions of the rights to acquire residential lot that was already of private ownership prior to
the approval of this Constitutions is applicable at the case at bar?

RULING:

2. Prior to the Constitution, there were in the Public Land Act No. 2874 sections 120 and 121 which granted aliens the
right to acquire private only by way of reciprocity. It is to be observed that the pharase "no land" used in this section
refers to all private lands, whether strictly agricultural, residential or otherwise, there being practically no private land
which had not been acquired by any of the means provided in said two sections. Therefore, the prohibition contained in
these two provisions was, in effect, that no private land could be transferred to aliens except "upon express
authorization by the Philippine Legislature, to citizens of Philippine Islands the same right to acquire, hold, lease,
encumber, dispose of, or alienate land." In other words, aliens were granted the right to acquire private land merely by
way of reciprocity.

Celso R. Halili & Arthur R. Halili v. CA, Helen Meyers Guzman,

David Rey Guzman and Emiliano Cataniag
G.R. No. 113539, March 12, 1998
Panaganiban, J..:

FACTS:
Petitioners appealed from the decision of the MTC and RTC ruling that Helen Guzmans (American citizen) waiver of her
inheritance in favor of her son was not contrary to the constitutional prohibition against the sale of land to an alien.

Simeon de Guzman, an American citizen, died sometime in 1968, leaving real properties in the Philippines. His forced
heirs were his widow, defendant appellee Helen Meyers Guzman, and his son, defendant appellee David Rey Guzman,
both of whom are also American citizens. Helen executed a deed of quitclaim assigning, transferring and conveying to
David Rey all her rights, titles and interests in and over six parcels of land which the two of them inherited from Simeon.
Subsequently, David Rey Guzman sold said parcel of land to defendant-appellee Emiliano Cataniag.

Petitioners, who are owners of the adjoining lot, filed a complaint questioning the constitutionality and validity of the
two conveyances and claiming ownership thereto based on their right of legal redemption under Art. 1621[5] of the Civil
Code.

ISSUES:

Were the petitioners entitled to a right of redemption?

Was the sale of the lot to defendant-appellee Cataniag valid?

HELD:

NO. The petitioners were not entitled to a right of redemption. The subject land is urban. Thus, petitioners have no right
to invoke Art. 1621 of the Civil Code, which presupposes that the land sought to be redeemed is rural.

YES. The sale to Cataniag is valid. Non-Filipinos cannot acquire or hold title to private lands or to lands of the public
domain. But what is the effect of a subsequent sale by the disqualified alien vendee to a qualified Filipino citizen?
Jurisprudence is consistent that if land is invalidly transferred to an alien who subsequently becomes a citizen or
transfers it to a citizen, the flaw in the original transaction is considered cured and the title of the transferee is rendered
valid. Since the disputed land is now owned by Private Respondent Cataniag, a Filipino citizen, the prior invalid transfer
can no longer be assailed. The objective of the constitutional provision -- to keep our land in Filipino hands -- has been
served.