CITY OF BAGUIO V MARCOS (1969)

CITY OF BAGUIO v MARCOS (1969)
G.R. No. L-26100

Justice Sanchez
FACTS:
• This case involves the challenge raised by the petitioners regarding the
jurisdiction of the Court of First Instance of Baguio to reopen cadastral
proceedings under Republic Act 931.
• On April 12, 1912, the cadastral proceedings sought to be reopened, were
instituted by the Director of Lands in the Court of First Instance of Baguio.
• On November 13, 1922, the land involved in the case was declared as public
lands and was rendered with finality.
• On July 25, 1961, private respondent, Belong Lutes, petitioned the cadastral
court to reopen said Civil Reservation Case No. 1 as to the parcel of land he
claims, mainly on the grounds that his predecessors had possession and
cultivation of the land, but because of illiteracy, they were not able to file a
claim within the statutory period.
• On December 18, 1961, private petitioners Francisco G. Joaquin, Sr.,
Francisco G. Joaquin, Jr., and Teresita J. Buchholz, (and later, City of Baguio)
opposed the reopening of the case on the grounds of being tree farm lessees
upon agreements executed by the Bureau of Forestry in their favor in three
dates in 1959.
• Initially, the cadastral court denied private petitioners' right to intervene in
the case because of a final declaratory relief judgment which declared that
such tree farm leases were null and void.
• Upon the petitioner’s motion, the cadastral court reversed its own ruling and
allowed petitioners to cross-examine the witnesses of respondent Lutes. The
opposition to reopening was ultimately dismissed by the court.
• City of Baguio moved to dismiss the petition to reopen, and the court denied
the motion to dismiss for lack of merit.
• The petitioners went to CA and filed certiorari, prohibition, and mandamus
with preliminary injunction, questioning the cadastral court's jurisdiction over
the petition to reopen.
• CA issued a writ of preliminary injunction and held that petitioners were not
bound by the declaratory judgment.
• However, CA also ruled private petitioners had no right to oppose the
reopening of the cadastral case. Their motion for reconsideration was also
denied.
• Petitioners elevated the case to the Supreme Court.
• The petitioners are contending the following:
o (1) the reopening petition was filed outside the 40-year period next
preceding the approval of Republic Act 931;
o (2) said petition was not published;
o (3) private petitioners, as lessees of the public land in question, have
court standing under Republic Act 931.
ISSUE:
W/N the reopening of the petition was filed outside the 40-year period next
preceding the approval of Republic Act 931 – NO
RULING:
• The Court, upon the examination of the title and the body of the statute
involved, resolved that reopening of the case was filed within the 40-year
period preceding the approval of RA 931. The basis of the ruling is the
following:
o RA 931 was enacted on June 20, 1953.
o The cadastral proceedings were instituted on April 12, 1912.
o The decision of the case was rendered on November 13, 1922.
o 1st Scenario: If the body of the statute is to be followed, the date of
institution of the case would determine if it was filed within the
allowable period. Should this scenario prevail, reopening of the case
would be deemed outside the allowable period.
o 2nd Scenario: If the title of the statue is to be followed, the date of
when the court rendered a decision would determine if it was filed
within the allowable period. Should this scenario prevail, reopening of
the case would be deemed inside the allowable period.
o Citing that the title of the law may properly be regarded as an
index of or clue or guide to legislative intention, the Court
resolved to adopt a liberal view of the remedial law, favoring
the petition to reopen the case.
• The Court leaned towards the liberal view of construing the statute. It cited
the long-accepted principle of remedial legislations receiving the blessings of
liberal construction.
• The title is not merely composed of catchwords, it expresses in language
clear the very substance of the law itself.
• The same inconsistency/imperfection in RA 931 attended its predecessor in
CA 276.
• Additionally, 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.
• As for the two other contentions of the petitioners, the Court ruled that the
petition need not to be published since the subject matter was already
embraced in the cadastral proceedings filed by the Director of Lands. The
court however, acceded that private petitioners have the necessary
personality to intervene in and oppose respondent Lutes' petition for
reopening.
FALLO:
• The Court granted the petition for certiorari, declared cadastral court orders
as null and void, and corrected the cadastral court to admit petitioner’s
oppositions and proceed accordingly.
DOCTRINE:
• The title is an indispensable part of a statute, and what may inadequately be

omitted in the text may be supplied or remedied by its title.
• Lingual imperfections in the drafting of a statute should never be permitted
to hamstring judicial search for legislative intent which can be discovered.
• Legal technicalities should not abort the beneficent effects intended by
legislation.
• The office of statutory interpretation is to determine legislative intent.
PROVISION
RA 931- "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."
"SECTION 1. All persons claiming title to parcels of land that have been the object of cadastral proceedings,
who at the time of the survey were in actual possession of the same, but for some justifiable reason had
been unable to file their claim in the proper court during the time limit established by law, in case such
parcels of land, on account of their failure to file such claims, 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, are hereby granted the right within five years 2 after the date on which this Act shall
take effect, to petition for a reopening of the judicial proceedings under the provisions of Act Numbered
Twenty-two hundred and fifty-nine, as amended, 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, and the competent Court of First Instance, upon receiving such petition, shall notify the
Government, through the Solicitor General, and if after hearing the parties, said court shall find that all
conditions herein established have been complied with, and that all taxes, interests and penalties thereof
have been paid from the time when land tax should have been collected until the day when the motion is
presented, it shall order said judicial proceedings reopened as if no action has been taken on such parcels."

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CITY OF BAGUIO v MARCOS (1969)

G.R. No. L-26100

• The title is an indispensable part of a statute, and what may inadequately be

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