City of Baguio vs. Marcos

CALIBUSO, JONA CARMELI B.
STATCON
CITY OF BAGUlO, REFORESTATION ADMINISTRATION,
FRANCISCO G. JOAQUIN, SR., FRANCISCO G. JOAQUIN, JR., and TERESITA J.
BUCHHOLZ petitioners,
vs.
HON. PIO R. MARCOS, Judge of the Court of First Instance of Baguio,
BELONG LUTES, and the HONORABLE COURT OF APPEALS, respondents.
G.R. No. L-26100

February 28, 1969
PRINCIPLES:
PURPOSE/OBJECT OF INTERPRETATION – Intent of the Legislative
To ascertain the legislative intent – look to the Title of the bill
R.A. 931 "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."
NATURE OF THE CASE:

ORIGINAL PETITION in the Supreme Court. Certiorari.
Petitioners attack the jurisdiction of the Court of First Instance of Baguio to reopen
cadastral proceedings under Republic Act 931. Private petitioner's specifically question the
ruling of the Court of Appeals that they have no personality to oppose reopening.
SC DECISION: FOR THE REASONS GIVEN, the petition for CERTIORARI is hereby
GRANTED; the cadastral court's orders of August 5, 1963, November 5,
1963 and September 17, 1964 are hereby declared null and void and the cadastral court is hereby
directed to admit petitioners' oppositions and proceed accordingly. No costs. So ordered.
FACTS: The cadastral proceedings sought to be reopened were instituted by the Director of
Lands in the Court of First Instance of Baguio. It is not disputed that the land here involved was
amongst those declared public lands by final decision rendered in that case on November 13,
1922.
Respondent Belong Lutes petitioned the cadastral court to reopen said Civil Reservation
Case No. 1 as to the parcel of land he claims. His prayer was that the land be registered in his
name.
But, private petitioners registered opposition to the reopening Ground: They are tree farm
lessees upon agreements executed by the Bureau of Forestry in their favor for 15,395.65 square
meters on March. 16, 1959, for 12,108 square meters on July 24, 1959, and for 14,771 square
meters on July 17, 1959, respectively.
Upon Lutes' opposition, the cadastral court denied private petitioners' right to intervene in
the case because of a final declaratory relief judgment dated March 9, 1962 in Yaranon vs.
Castrillo [Civil Case 946, Court of First Instance of Baguio] which declared that such tree farm
leases were null and void.
Private petitioners moved to reconsider. They averred that said declaratory relief
judgment did not bind them, for they were not parties to that action.
ISSUE: 1. WON the private petitioners have personality in opposing the reopening of the
cadastral proceeding. (YES)
STATCON
2. WON the reopening petition was filed outside the 40-year period next preceding the
approval of Republic Act 931. (NO)
RULING:
1. YES. The case at bar involves a special statute R.A. 931, which allows a petition for
reopening on lands "about to be declared" or already "declared land of the public
domain" by virtue of judicial proceedings. Such right, however, is made to cover limited
cases, i.e., "only with respect to such of said parcels of land as have not been alienated,
reserved, leased, granted, or otherwise provisionally or permanently disposed of by the
Government." The lessee's right is thus impliedly recognized by R.A. 931. This
statutory phrase steers the present case clear from the impact of the precept forged by
Leyva. So it is, that if the land subject of a petition to reopen has already been leased by
the government, that petition can no longer prosper.
This was the holding in Director of Land vs. Benitez, L-21368, March 31, 1966. The
reopening petition there filed was opposed by the Director of Lands in behalf of 62 lessees of
public land holding revocable permits issued by the government. We struck down the petition in
that Case because the public land, subject-matter of the suit, had already been leased by the
government to private persons.
The right of private petitioners to oppose a reopening petition here becomes the more
patent when we take stock of their averment that they have introduced improvements on the land
affected. It would seem to us that lessees insofar as R.A. 931 is concerned, come within the
purview of those who, according to the Rules of Court, 8 may intervene in an action. For, they
are persons who have "legal interest in the matter in litigation, or in the success of either of the
parties." In the event herein private petitioners are able to show that they are legitimate lessees,
then their lease will continue. And this because it is sufficient that it be proven that the land is
leased to withdraw it from the operation of Republic Act 931 and place it beyond the reach of a
petition for reopening.
In line with the Court of Appeals' conclusion, not disputed by respondent Lutes herein,
the cadastral court should have ruled on the validity of private petitioners 'tree farm leases — on
the merits. Because there is need for Lutes' right to reopen and petitioners' right to continue as
lessees to be threshed out in that court.
2. NO. Republic Act 931,effective June 20, 1953.
Declared Public Land Decision 1922-------------40 years-----------------1953 law effective
The cadastral proceedings sought to be reopened were instituted on April 12, 1912.
Final decision was rendered on November 13, 1922. Respondent Lutes filed the petition
to reopen on July 25, 1961.
It will be noted that the title of R.A. 931, heretofore transcribed, 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."
The body of the statute, 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 thus appears to be a seeming inconsistency between title and body.
STATCON
The office of statutory interpretation, let us not for a moment forget, is to determine
legislative intent. In the words of a well-known authority, "[t]he true object of all
interpretation is to ascertain the meaning and will of the law-making body, to the end that
it may be enforced."
In fact, "the spirit or intention of a statute prevails over the letter thereof." 15 A
statute "should be construed according to its spirit and reason, disregarding as far as
necessary, the letter of the law." 16 By this, we do not "correct the act of the Legislature,
but rather ... carry out and give due course to" its true intent.
It should be certain by now that when engaged in the task of construing an

obscure expression in the law 18 or where exact or literal rendering of the words would
not carry out the legislative intent, 19 the title thereof may be resorted to in the
ascertainment of congressional will. Reason therefor is that the title of the law may
properly be regarded as an index of or clue or guide to legislative intention.
R.A. 931, viz: "AN ACT TO AUTHORIZE 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."
It expresses in language clear the very substance of the law itself. From this, it is easy to
see that Congress intended to give some effect to the title of R.A. 931.
It has been observed that "in modern practice the title is adopted by the
Legislature, more thoroughly read than the act itself, and in many states is the subject of
constitutional regulation." The constitutional in jurisdiction that the subject of the statute
must be expressed in the title of the bill, breathes the spirit of command because "the
Constitution does not exact of Congress the obligation to read during its deliberations the
entire text of the bill."
Reliance, therefore, may be placed on the title of a bill, which, while not an
enacting part, no doubt "is in some sort a part of the act, although only a formal part."
The title now under scrutiny possesses the strength of clarity and positiveness. It
recites that it authorizes court proceedings of claims to parcels of land declared public
land "by virtue of judicial decisions rendered within the forty years next preceding the
approval of this Act."
The sum of all the foregoing is that, as we now view Republic Act 931, claims of
title that may be filed thereunder embrace those 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." Therefore, by that statute, the July 25, 1961 petition of
respondent Belong Lutes to reopen Civil Reservation Case No. 1, GLRO Record No. 211
of the cadastral court of Baguio, the decision on which was rendered on November 13,
1922, comes within the 40-year period.lawphi1.nêt
FOR THE REASONS GIVEN, the petition for certiorari is hereby granted; the
cadastral court's orders of August 5, 1963, November 5, 1963 and September 17, 1964
are hereby declared null and void and the cadastral court is hereby directed to admit
petitioners' oppositions and proceed accordingly. No costs. So ordered.

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CALIBUSO, JONA CARMELI B.

G.R. No. L-26100

PURPOSE/OBJECT OF INTERPRETATION – Intent of the Legislative

To ascertain the legislative intent – look to the Title of the bill

NATURE OF THE CASE:

2. NO. Republic Act 931,effective June 20, 1953.

Declared Public Land Decision 1922-------------40 years-----------------1953 law effective

It should be certain by now that when engaged in the task of construing an

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