Director of Lands v. Ocampo
REITERATIONFacts
The Antecedents: A decision was rendered in cadastral case No. 13, declaring cadastral lot No. 1368 as public land. Subsequently, the Philippine Legislature passed Act No. 3672, authorizing the filing of claims for lands declared public land within one year from the promulgation of the Act. The Governor-General issued Proclamation No. 299 on February 28, 1930, announcing the approval of Act No. 3672 by the President of the United States on February 7, 1930. Later, Proclamation No. 307 was issued on March 26, 1930, amending Proclamation No. 299 to correct the approval date to February 17, 1930. Procedural History: On March 12, 1931, Ambrosio Manuel filed a motion to set aside the default order and the decision concerning lot No. 1368, and to have the lot adjudicated to him. The respondent judge issued an order on March 28, 1931, cancelling the previous decision and admitting Manuel's answer. The Director of Lands filed a motion for reconsideration, arguing that Manuel's motion was filed beyond the one-year period. This motion was denied, and on May 18, 1931, the respondent judge rendered a partial decision adjudicating lot No. 1368 to Ambrosio Manuel. The Petition: The Director of Lands, represented by the Attorney-General, filed a certiorari proceeding to annul and set aside the orders and the partial decision of the respondent judge, contending that the respondent Manuel's motion was filed out of time.
Issue(s)
Whether the motion filed by respondent Ambrosio Manuel on March 12, 1931, was filed within the one-year period fixed in Section 1 of Act No. 3672, which involves the computation of said period.
Ruling
The petition for certiorari is denied. The orders and partial decision of the respondent judge are declared valid and lawful.
Ratio Decidendi
On Issue 1: The Supreme Court ruled that the one-year period for filing claims under Act No. 3672 commenced from March 26, 1930, which is the date of Proclamation No. 307. The Court reasoned that Proclamation No. 307 explicitly amended Proclamation No. 299 to correct a substantial error regarding the date of approval of Act No. 3672 by the President of the United States. While Proclamation No. 299 initially announced the approval on February 7, 1930, Proclamation No. 307 clarified that the actual approval occurred on February 17, 1930. The Court emphasized that this amendment was substantial because the date of the President's approval was the fundamental basis for the Governor-General's proclamation, which, in turn, dictated when Act No. 3672 would take effect. Therefore, Proclamation No. 307 was understood to have abrogated, by amendment, Proclamation No. 299, making the later date of March 26, 1930, the proper commencement date for the one-year statutory period. Since Ambrosio Manuel's motion was filed on March 12, 1931, it was well within the one-year timeframe from March 26, 1930, rendering the respondent judge's actions valid and within his jurisdiction, thus warranting the denial of the petition for certiorari.
Main Doctrine
The period for filing claims under Act No. 3672 commences from the date of the last proclamation that corrects an error in a previous proclamation regarding the approval of the Act by the President of the United States, not from the date of the initial proclamation or the publication of the law.