Municipality of Taytay v. Director of Lands
REITERATIONFacts
The Antecedents: The Municipality of Taytay applied for the registration of two parcels of land. In a prior proceeding in 1905, the parish of Taytay had applied for the registration of a larger parcel of land, which included the two parcels in question. In that prior proceeding, both the Municipality of Taytay and the Insular Government opposed the application. The Court of Land Registration denied the inscription, and this Court affirmed the decision. Procedural History: In the present registration proceeding (No. 674, G. L. R. O. record No. 30408), the Municipality of Taytay again applied for the registration of the two parcels of land. The Director of Lands, on behalf of the Insular Government, opposed the application. The trial court, applying Act No. 3621, upheld the opposition and denied the application, decreeing that the lands are public lands belonging to the Government of the Philippine Islands. The Petition: The Municipality of Taytay appealed the decision, assigning several errors, primarily arguing that the lands in dispute belong to the category of "Bienes de propis y bienes patrimoniales" of the municipality and that there is a presumption of grant in its favor due to long possession and use for public character.
Issue(s)
Whether the lands in dispute belong to the category of "Bienes de propis y bienes patrimoniales" of the municipality of Taytay. Whether there is a presumption of grant in favor of the municipality of Taytay despite its long possession and use of the land for public purposes. Whether the doctrine laid down in previous cases, particularly Municipality of Tacloban vs. Director of Lands, applies to the present case. Whether the lands in dispute should be registered in the name of the Government of the Philippine Islands.
Ruling
The judgment appealed from is affirmed, with the modification that the right of the inhabitants of the municipality of Taytay to use and avail themselves of the products thereof shall be recorded in the registry, and the passage referring to reimbursement of expenses shall be eliminated. The lands in question are decreed to be public lands and are to be recorded in the name of the Government of the Philippine Islands.
Ratio Decidendi
On whether the lands belong to the municipality as "Bienes de propis y bienes patrimoniales": The Court held that the municipality failed to establish its ownership. The evidence presented, including ancient documents and receipts for lease and collection of rents, only demonstrated possession and the collection of income. However, mere leasing and receiving rent, without other proof, cannot support a claim of ownership. The Court reiterated the principle that municipalities are not entitled by right to any part of the public domain for use as communal lands; the usufruct of a portion of the public domain might be granted, but the ultimate title remained in the sovereign. On the presumption of grant: The Court found no presumption of grant in favor of the municipality. The Royal Decree of September 20, 1656, cited by the municipality, merely protected the officials and natives in their possession and any right they might have upon the river and shoals, not permitting others to fish within their boundaries. This protected possession was for the common benefit of the inhabitants, not for the municipality to become its own private property. The Court emphasized that for a municipality to be considered proprietor with a right to inscription, it must be shown that the land was granted by the Government or that a municipal building was erected thereon for public purposes, which would lead to a presumption of a grant. On the applicability of previous doctrines: The Court applied the doctrines laid down in Municipality of Tacloban vs. Director of Lands and Municipality of Tigbauan vs. Director of Lands. These cases established that the mere enjoyment of the usufruct of public land, such as cutting cane or planting trees, does not grant the right to have the property registered as the municipality's own. The Court also referenced its own decisions declaring that ownership of lands not subject to acquired rights, and included within municipal boundaries under Spanish sovereignty, remained in the King, not in the municipality as a corporation. Therefore, the land in question belonged to the Crown of Spain and subsequently to the public domain of the United States. On the registration in favor of the Government: Based on the foregoing, the Court concluded that the lands in dispute are public lands. The municipality's claim of ownership was not substantiated by sufficient evidence to overcome the presumption that lands not granted remain part of the public domain. The prior decision in G. L. R. O. record No. 11271, where similar evidence was presented and the application denied, further supported this conclusion. The Court found no reason to alter the findings and conclusions of the previous case, considering the long series of decisions on the matter.
Main Doctrine
Municipalities cannot claim ownership over lands that have not been granted to them by the government, even if they have been in possession for a long time and have derived income therefrom for public use. Such possession and use only grant usufructuary rights, with the ultimate title remaining in the sovereign.