SUSI vs RAZON and Director of Lands, G.R. No.

L-24066

FACTS:
1. By way of a deed of sale, Susi bought the subject land which was then a fish
pond sold by its original owner Nemesio Pinlac to Apolonio and Basilio
Mendoza and eventually to Susi, bought in the amount of P12 with right to
repurchase; Susi has alwasys been in open, continuous, notorious and
exclusive possession since then except when there is revolution, war, or
disturbance.
2. However, on September 13, 1913, Razon commenced an action in RTC
Pampanga to recover the possession over the said land which the court
dismissed. This now led for Razon to obtain possession of the land by
applying and purchasing the same which Susi opposed the said sale but the
Director of Lands overruled the opposition and sold the land to Razon who
succeeded in registering the land and securing a certificate thereto. Razon
even filed cases for forcible entry against Susi which was dismissed for lack
of jurisdiction.
3. For the abovementioned reasons, a complaint was filed by plaintiff Susi in
the RTC of Pampanga against the respondents Razon and the Director of
lands praying that the judgment be rendered as follows:
a. She be declared the sole and absolute owner of the parcel of land
described in the second paragraph of the complaint;
b. Annul the sale executed by the Director of Lands to Razon on the ground
that the same is already privately owned;
c. Order the cancellation of the certificate of title of Razon; and
d. Pay Susi the sum of P500 pesos as damages
4. The Director of Lands denied the allegations and as a special defense,
alleged that the subject property is owned by the government of US under
the administration of the Philippines, before it was sold to Razon, which
was in accordance with the law.
5. After trial, the lower court rendered judgment in favor of Susi. Thereafter,
the respondent made an appeal to CA.

ISSUE:
Between Susi and Razon, who has better title over the subject land in dispute, the
one who acquirer and registered the land or the one who has been in open,
continuous, notorious and exclusive possession of the land?

HELD:

The court ruled citing the case of Carińo vs Government of the Philippine Islands
in favor of Valentin Susi citing paragraph b of Section 45 of Act No. 2874, which
amended Act No. 926 regarding the presumption juris et de jure. That before
Angela Razon applied for grant in her favor, Valentin Susi had already acquired
the land by operation of law. She has already been in actual and physical
possession of the land, personally through her predecessors, of an agricultural
land of the public domain, openly, continuously, exclusively and publicly since July
26, 1894 tacked from the possession of the original owner. Under the said law, it
was not necessary that a certificate of title be issued in order that the said grant
may be sanctioned by the courts, an application thereof is sufficient. By legal
fiction, Susi had acquired the land in question by a grant of the State, it had
already ceased to be public domain and had become private property, at least by
presumption, and beyond the control of the Director of Lands; thus, it cannot
dispose the land to Razon and the sale be declared null and void. The Court
affirme the decision of the lower court.

McDaniel vs Apacible, Sec, of Agriculture and Natural Resources and Cuisia, G.R.
No. L-17597

FACTS:
1. The herein plaintiff is the attorney-in-fact and agent of an association
whose members/composition are citizens of US or of the Philippines,
entered on an unoccupied public land situated in the municipality of San
Narciso, Tayabas and located, in accordance with the provision of Act No.
624 of the Philippine Commission, three “association” petroleum placer
claims, each of 64 HA; registered the “three” association claims with the
municipality of Tayabas under the names, “Maglihi 1, 2 and 3” respectively.
2. They remained in possession of the claim from July 7, 1916 to October 17,
1917; thus, the other entire member sold all their right, title and interest
over the same to the herein petitioner. The plaintiff remained in possession
of it and in the year 1917 has exerted labor of P200 worth on each.
3. In 1918, out from drilling wells, discovered petroleum on the 3 claims
whereby the plaintiff expended sum of approximately P12,000
4. On January 18, 1921, the herein defendant Juan Cuisia made application
before the office of Secretary of Agiculture and Natural Resources (now
DENR) for brevity, Sec. of ANR, under the provisions of Act No. 2932 of the
Philippine Legislature, for lease of a parcel of petroleum before the
municipality of San Narciso, Tayabas with the inclusion of “Maglihi 1, 2 and
3”. Upon the application, McDaniel protested against the inclusion of the
land held by him, by writing the Secretary of ANR. However, the same was
denied.
5. The plaintiff was informed that Rafael Corpus (Secretary of ANR)under the
authority of Act No. 2932, is about to grant the lease application to Juan
Cuisia included that being held by the herein plaintiff.
ISSUE:
1. Whether Act No. 2932 of the Philippine Legislature, in so far as it purports
to declare open to lease lands containing petroleum oil on which mineral
claims have been validly located and held, and upon which discoveries of
petroleum oil have already been made, is void and unconstitutional.

2. Whether the Sec. of ANR have jurisdiction to lease Maglihi 1, 2 and 3.

HELD:
The Court decided in favor of McDaniel. It held the case as follows:
1. The Court held that inasmuch as the petitioner had located, held and
perfected his location of the mineral lands in question, and had actually
discovered petroleum oil therein; he had acquired a property right in said
claims: thus, Act No. 2932, which deprives him of such righty, without due
process of law, is in conflict with the section 3 of the Jones Law, and is
therefore unconstitutional and void.

2. Under the provisions of the said Act, the authority of the Sec. of ANR to
make such lease is confined to lands containing petroleum and other
mineral oils and gas in the Philippine Islands. In the given case, it shall be
noted that the original locations were valid and that P12, 000 have been
expended by the herein petitioner for the development, and there being no
plea of forfeiture to do the annual assessment work, and that the records
show that the original locations were made in good faith, the lands
containing petroleum and other mineral oils, the plaintiff is entitled to the
relief being prayed for.

The growth and development of minerals add new resources and

undiscovered wealth to a country, and provide employment for labor. For
such reasons, it has always been the policy of the mining law to encourage
the prospector. He had been the pioneer in the discovery of minerals in all
countries, and often his task had been sad and lonely, and he has had many
bitter disappointments.

VICENTE ABAOAG, et.al vs the Director of Lands, G.R. L-20875

FACTS:
1. Since 1884, records show that a number of (about 30) “Bogos” or Igorots
or Non-Christians were invited by the Gobernadorcillo and Principalia to
the town of Alava (now Sison, Pangasinan), to cultivate and increase
their population over the said municipality comprising an agricultural
 land area of 77HA, 40 ares and 50 centinares; the herein applicants are
descendants thereto.
2. It was on February 28, 1919 that the herein petitioner presented a
petition in the Court of First Instance (now RTC) Pangasinan, in order to
register the said land under the Torrens System; it was accompanied by
an official plan prepared by the Director of Lands. Thereafter, a new plan
and technical description was required to them by the said government
agency.
3. During the trial, a number of witnesses were presented but the petition
of the applicants was dismissed on the ground that the applicants had
had not presented sufficient proof to show that they are entitled to the
registration of the land in question.
4. The applicants presented motion for new trial but the same was denied
and so case was appealed to the higher court.
5. The contention of the descendants is that they were given the land by
the Gobernadorcillo and Principalia; they accepted it; they openly,
continuously, exclusively and notoriously lived, cultivated, improved and
occupied the land for about 39 years to the exclusion of others thereby
entitling them to register the same under the Torrens System.
ISSUE:
Are the applicants entitled to register the land subject of dispute under the
Torrens System despite it being a public land?
HELD:
The Court ruled in favor of the petitioners, citing the case of Cariňo vs Insula
Government (7 Phil. 132). In the course of that decision, Justice Holmes said
that the acquisition of the Philippines was not for the purpose of acquiring
the lands occupied by the inhabitants, and under the Organic Act of July 1,
1902, providing that property rights are to be administered for the benefit
of the inhabitants, one who actually owned land for many years cannot be
deprived of it for failure to comply with certain ceremonies prescribed
either by acts of the Philippine Commission or by the Spanish Law; every
presumption is ought to be against the government. If there is doubt or
ambiguity in the Spanish law, the applicants must be given the benefit of
the doubt.
The Court reversed the decision of the lower court; the applicants were
given permission to amend their petition to what is wise and necessary as
they may desire.