BAGUIO V MARCOS

FACTS:
- On April 12, 1912, the Director of Lands in the Court of First Instance of Baguio instituted the cadastral
proceedings which involved a declared public land as rendered in a decision on November 13, 1922.
-Respondent Belong Lutes petitioned the cadastral court to reopen and prays that the land be registered in
his name. Private petitioners registered opposition to the reopening.
-The City of Baguio likewise opposed reopening.
- Petitioner contends that (1) the reopening petition was filed outside the 40-year period next preceding the
approval of Republic Act 931; (2) said petition was not published; and (3) private petitioners, as lessees of
the public land in question, have court standing under Republic Act 931.

ISSUE:
Whether or not the reopening petition was filed outside the 40 year period preceding the approval of
Republic Act 931.

HELD:
Yes. The court allowed the reopening of the case since the case was filed within the 40-year period imposed
by the act.

R.A. 931 authorizes "the filing in the proper court, under certain conditions, of certain claims of title to
parcels of land that have been declared public land, by virtue of judicial decisions rendered within the forty
years next preceding the approval of this Act." However, in its Section 1, speaks of parcels of land that
"have been, or are about to be declared land of the public domain, by virtue of judicial proceedings instituted
within the forty years next preceding the approval of this Act. There is inconsistency between the title and
body.

If the wordings of Sec. 1 are to be followed, the date April 12, 1912, which is the date the Director of lands
instituted the reopening of the case, would render the petition invalid since it is already outside the 40-year
period. If the title is to be followed, November 13, 1922 is the date which should be followed, hence, would
allow the reopening of the case.

The rule on statutory construction provides that laws should be construed liberally. The spirit or the intent of
the law should be looked upon and should prevail over its letter. In this case, R.A. 931 clearly gives an
opportunity to any person who has any interest in any parcel of land which has been declared as public land
to present his claim within the time prescribed.

STAT CON:
* intrinsic aids

The title is an indispensable part of a statute, and what may inadequately be omitted in the text may be
supplied or remedied by its title.

The title of the law may be resorted to in the ascertainment of legislative intent.