Municipality of Tigbauan v. Director of Lands
REITERATIONFacts
The Antecedents: The Municipality of Tigbauan applied for the registration of seven parcels of land, claiming ownership by continuous possession since time immemorial. The Director of Lands opposed the registration of parcels Nos. 1, 6, and 7, asserting that parcel No. 1 was a public square and parcels Nos. 6 and 7 were government property. The applicant withdrew its claim for parcel No. 1 but maintained its claim for parcels Nos. 6 and 7. Procedural History: The Court of First Instance of Iloilo ruled in favor of the municipality, adjudicating parcels Nos. 6 and 7 to it, and disallowed the Director of Lands' adverse claim. The court based its decision on sections 38 and 41 of the Code of Civil Procedure regarding prescription. The Director of Lands appealed, arguing that the trial court erred in applying the provisions on prescription and in decreeing the adjudication and registration. The Petition: The appellant (Director of Lands) contended that the trial court erred in applying sections 38 and 41 of the Code of Civil Procedure to parcels Nos. 6 and 7 and in denying a new trial on this basis. The appellant also argued that the trial court erred in decreeing the adjudication and registration of these parcels in favor of the municipality, disallowing the adverse claim.
Issue(s)
Whether the Municipality of Tigbauan is entitled to the adjudication and registration of parcels Nos. 6 and 7 based on prescription. Whether the trial court erred in applying sections 38 and 41 of the Code of Civil Procedure to the case. Whether the municipality can acquire ownership of public lands through prescription.
Ruling
The Supreme Court reversed the judgment of the lower court, denying the adjudication and registration of parcels Nos. 6 and 7 in favor of the Municipality of Tigbauan and sustaining the adverse claim of the Director of Lands.
Ratio Decidendi
On the entitlement to adjudication and registration based on prescription: The Court held that the municipality cannot be considered the owner of parcels Nos. 6 and 7, nor is it entitled to register them. The evidence showed that the municipality had gathered cane from the canebreaks on these parcels and planted caña espina trees, but this only demonstrated a usufructuary right, not ownership. The lands were surrounded by public lands, and the adjacent property owners were mere occupants. There was no proof that these parcels were ever private property or granted by the Government to the municipality as part of its assets. The Court reiterated the principle that mere collection of revenues or rentals from occupants of land does not prove municipal ownership, but at most, a usufructuary right without the title to register. On the application of sections 38 and 41 of the Code of Civil Procedure: The Court found that the trial court erred in applying the provisions on prescription to the parcels in question. These sections relate to prescription, which is a means of acquiring ownership. However, the Court clarified that municipal corporations, due to their nature and functions, cannot engage in agriculture or private business without detriment to public interests. Therefore, they cannot benefit from provisions like section 54 of Act No. 926, which fosters agriculture. The Court emphasized that the lands in question are agricultural and communal lands, not lands that a municipality can exclusively own for public necessity. Consequently, the municipality could not invoke prescription under sections 38 and 41 of the Code of Civil Procedure to acquire title to these government lands. On the acquisition of ownership of public lands through prescription by municipalities: The Court definitively ruled that municipalities cannot acquire ownership of public lands through prescription. Act No. 648 of the Philippine Commission authorizes the Governor-General to reserve public lands for public uses, indicating that municipalities cannot appropriate public lands without a prior grant from the Government and proper reservation procedures. The Court cited previous decisions, including Municipality of Tacloban vs. Director of Lands, which established that for a municipality to presume a grant from the State, the land must be used for purposes meeting a public necessity and originally granted for such purposes. Agricultural or communal lands are not susceptible to this presumption. Therefore, the municipality's claim based on prescription was unfounded.
Main Doctrine
Municipal corporations cannot acquire ownership of public lands through prescription, nor can they appropriate such lands without a prior grant from the Government and reservation in the manner specified by law. The mere use or collection of revenues from lands does not establish ownership, but at most, a usufructuary right without the title to register.