Director of Lands v. Garrido
REITERATIONFacts
The Antecedents: Several claimants in a cadastral case filed a petition to dismiss the proceedings, challenging the constitutionality of Act No. 3327 and alleging illegality in the cadastral project of Jaro, Leyte. Procedural History: The Court of First Instance of Leyte denied the claimants' motion to dismiss. The Petition: The claimants appealed, arguing that Act No. 3327 is unconstitutional because it deprives persons of property without due process and curtails their right to dispose and enjoy it, and imposes seizure of property as a penalty. They also contended that even if constitutional, the Jaro, Leyte cadastral project was illegal due to non-compliance with Act No. 3327, specifically regarding the non-existence of the contracting corporation at the time of filing and the falsity of the municipal council's approval, and that the field work was not in accordance with Bureau of Lands regulations. They further argued that the court lacked jurisdiction due to non-fulfillment of legal formalities.
Issue(s)
Whether Act No. 3327 is unconstitutional for allegedly depriving persons of property without due process and curtailing their right to dispose and enjoy it. Whether the cadastral project of Jaro, Leyte, is null, void, and illegal for failure to comply with Act No. 3327 and its regulations. Whether the court has jurisdiction to proceed with the case.
Ruling
The Supreme Court affirmed the order of the Court of First Instance of Leyte, denying the motion to dismiss and upholding the constitutionality of Act No. 3327 and the validity of the cadastral proceedings.
Ratio Decidendi
On the constitutionality of Act No. 3327: The Court held that while the rights to contract and to property are fundamental, they are not absolute and are subordinate to the police power of the State. Act No. 3327, particularly its provisions for prompt and speedy registration of land titles, serves the public weal and does not unduly abridge the right to contract freely. Compulsory registration, as provided, allows for due process to all interested parties. The Court cited several previous rulings to support the principle that the prompt registration of titles advances public interests, promotes peace and good order, increases industries, and develops natural resources, all of which are legitimate aims of the State's police power. On the alleged unconstitutionality of Section 3 of Act No. 3327: The Court found no impropriety in Section 3, which provides that default in the payment of survey fees shall be treated similarly to default in the payment of taxes. This provision is part of the general scheme to promote the public weal. The Act ensures that the fees are not left to the sole discretion of surveyors but require sanction and approval from municipal councils and provincial boards, and endorsement to the Governor-General, provided the project is reasonable and equitable. The various provisions of Act No. 3327 surround the payment of fees with guarantees safeguarding both public interest and individual rights. On the alleged illegality of the cadastral project and lack of jurisdiction: The Court did not find merit in the specific allegations regarding the non-existence of the corporation, the falsity of the municipal council's approval, or the non-compliance with Bureau of Lands regulations. The Court's affirmation of the constitutionality of the Act and its general scheme implies that the procedural requirements, when properly followed, are sufficient to grant the court jurisdiction. The denial of the motion to dismiss by the lower court, which was affirmed on appeal, indicates that the procedural and substantive challenges raised by the claimants were found to be without basis.
Main Doctrine
The State, in the exercise of its police power, may enact laws that regulate and restrict property rights and the right to contract for the promotion of the public weal, such as ensuring prompt and speedy registration of land titles. Provisions for compulsory registration and the imposition of penalties for non-payment of survey fees, when surrounded by adequate governmental safeguards, do not violate constitutional rights.