Cario v.

Insular Government 212 US 449, February 23, 1909

FACTS:
This was an application to the Philippine Court of Land Registration (CLR) for the registration of certain
land on June 23, 1903 to petition his inscription as the owner of a 146 hectare land hes been possessing for
more than fifty years before the Treaty of Paris, April 11, 1899, as far back as the findings go, the plaintiff
and his ancestors had held the land as owners in the municipality of Baguio. The application was granted
by the court on March 4, 1904. However, an appeal was taken to the Court of First Instance of the Province
of Benguet on behalf of the government of the Philippines and also on behalf of the United States, those
governments having taken possession of the property for public and military purposes.
The Court of First Instance found the facts and dismissed the application upon grounds of law. This
judgment was affirmed by the supreme court, 7 Phil. 132, and the case then was brought here by writ of
error because the material facts found are very few. The applicant and plaintiff in error is an Igorot of the
Province of Benguet, where the land lies. Mateo averred that a grant should be given to him by reason of
immemorial use and that the right of the State over said land has prescribed.
ISSUE:
Whether or not Mateo is the rightful owner of the land by virtue of his possession of it for some time.
- How far a new sovereign shall insist upon the theoretical relation of the subjects to the head in past and how fat it
shall recognize actual facts, are matter to decide?
- What property and rights the United States asserted itself to have acquired?
Whether justice to the natives and the import of the organic act ought not to carry us beyond a subtle
examination of ancient texts, or perhaps even beyond the attitude of Spanish law, humane though it was, it
is unnecessary to decide.
HELD:
No. The statute of limitations did not run against the government. The government is still the absolute
owner of the land (regalian doctrine). Further, Mateos possession of the land has not been of such a
character as to require the presumption of any royal grant. No one has lived upon it for many years. It was
never used for anything but pasturage of animals, except insignificant portions thereof, and since the
insurrection against Spain it has apparently not been used by Cario for any purpose.
While the State has always recognized the right of the occupant to a deed if he proves a possession for a
sufficient length of time, yet it has always insisted that he must make that proof before the proper administrative
officers, and obtain from them his deed, and until he did the State remained the absolute owner.