LAND TITLES BLOCK DIGEST

Atty. Lorenzo Padilla – 1st semester, A.Y. 2020-2021

GROUP 1

GOLLOY v CA, G.R. No. L-47491, Date (4 MAY 1989)

FACTS: In the case of Golloy v. CA, the petitioner is the registered owner of a parcel of land for over 20 years. Southwest to
this is a land bounded by the respondent’s land. When the private respondents subdivided their land among themselves, 2
monuments were placed inside the portion of land owned by the petitioner. This prompted the petitioner to file an action to
quiet the title. The two parties agreed that their argument stems from the question of their respective land’s boundaries. The
Trial Court ordered the Director of Lands to appoint an impartial land surveyor to conduct a survey on the area. From the
finding of the surveyor, it was found that the overlapping in the lands were due to a defect in the petitioner’s land since it did
not conform to the previously approved survey. He recommended that the respondents have a better claim to the land since
they had the title. RTC ruled in favor of the Respondents, Appeal was denied.

ISSUE: Who has the legal right to claim the overlapping portions of land? - Petitioners.
RULING: The Supreme Court ruled that the petitioner has the right and claim over the overlapping portions of land due to the
laches of the respondents. The respondent’s predecessors never believed that she had such right or claim over the disputed
land since she made no objections over the 50-year ownership of the petitioner and his predecessors. Therefore, respondents
even if they have any right to the land, they are guilty of laches. The petitioners have acquired title to it by virtue of the
equitable principle of laches due to respondent's failure to assert their claims and ownership
“For, mere possession of certificate of title under the Torrens System is not conclusive as to the holder's true ownership of all
the property described therein for he does not by virtue of said certificate alone become the owner of the land illegally
included."

REPUBLIC OF THE PHILIPPINES v COURT OF APPEALS, G.R. No. L-313103, Date (31 MAY 1978)
FACTS:  The petitioners were contending that they were the rightful owners of a parcel of land. They state that it was donated
by a certain Jalondoni in his will in September 1926, however the respondents in this case assert that the land is theirs because
of a donation by a certain Luis Mosquera in November 1911.
This dispute went to trial wherein the trial court ruled in favor of the respondents, the Republic appealed the ruling 4 months
after, this delay was attributed by the Republic to the “excusable negligence” committed by their docket clerk. This appeal
was given due course by the trial court, but they ultimately ruled in favor of the respondents. The petitioners then appealed to
the Court of Appeals wherein the appeal was dismissed due to the fact that it was filed 6 days after the reglementary period
and its extension.

ISSUE: W/N the Republic of the Philippines can be guilty of laches - YES

RULING: Supreme Court ruled that while the Republic may be guilty of laches and negligence, the rules may be relaxed
when compelling reasons arise, which in this case is the gross injustice suffered when the respondents fraudulently perfected
their title.

TONGSON v DIRECTOR OF FORESTRY, G.R. No. L-34463, Date (27 SEPTEMBER 1977)
FACTS:  In the case of Tongson v Director of Forestry, testimonial evidence shows that a parcel of land, to which the subject
lot belongs, was under the exclusive possession of one Francisco Borja. Borja cut trees for firewood in the land. It was alleged
that the land at that time was a mangrove swamp. After subsequent transfers, a portion of the land was transferred to Santiago
Bermejo. After Santiago’s death, Macario Bermejo, his heir and administrator, converted the land into a fishpond

ISSUE: W/N a parcel of land, possessed as far back as 1905, which has been alleged to be a mangrove swamp and converted
into a fishpond, is considered as part of the timber domain, and thus is not disposable and cannot be registered. - NO

RULING: The possession of Borja and the subsequent owners was peaceful, continuous, open, and adverse under claim of
ownership for a period of not less than 50 years. The application for registration must be granted.
Besides, the definition of ‘forestry; as including manglares found in the Administrative Code of 1917 cannot affect rights
which are vested prior to its enactment. The applicable law is the Act of Congress of July 1st 1902. The Act classifies the
public lands in the Philippine Islands as timber, mineral or agricultural lands, and all public lands that are not timber or
mineral lands are necessarily agricultural public lands, whether they are used as nipa swamps, mangroves, fisheries, or

1
ordinary farmlands. Therefore, mangrove lands are not forest lands in the sense in which this phrase is used in the Act of
Congress. So even if the subject land was indeed a mangrove land, it still does not make it into an inalienable forest land.

“Mangrove swamps where only trees of mangrove species grow, where the trees are small and sparse, fit only for firewood
purposes and the trees growing are not of commercial value as lumber do not convert the land into public land. Such lands are
not forest in character. They do not form part of the public domain.”

AMPOLOQUIO v COURT OF APPEALS, G.R. No. 46800-001, Date (29 APRIL 1994)
FACTS:  Respondent Salvador Zartiga claimed ownership over nine (9) lots with a total area of more or less 289.9920
hectares. He claimed that he had been the absolute owner and possessor of said parcels of land, having bought the same from
Datu Julian Bagobo under a deed executed in 1927, but that petitioners had occupied certain portions of the nine (9) lots,
about forty-nine (49) hectares of the 285 hectares, without his knowledge and consent. Petitioners, on the other hand, denied
private respondent's ownership and alleged that the land in question is public land; that neither private respondent nor his
predecessor-in-interest had occupied the property.
The Director of Lands intervened, asserting the property subject matter of Civil Case No. 670 to be "public agricultural land,
owned by the Government of the Republic of the Philippines.
The Municipality of Bansalan, on its part, filed an opposition to the petition on the ground that the nine (9) parcels of land
included in the petition for registration were reserved for townsite of, and actually occupied by, the Municipality of Bansalan.
Evidence was introduced to the effect that about 10,000 people inhabited the poblacion of Bansalan and that approximately
500 buildings, private and government-owned, as well as schools, markets, religious, commercial and residential structures,
and other constructions, including municipal roads and other infrastructures, already stood in place within the disputed area.
The trial court and Court of appeals ruled in favour of Zartiga and awarded him the Lots No. 2326, 2325, 2342, 2343, 2344
and 2416

ISSUE: W/N not the disputed lands were part of the public domain, making them unregistrable – YES

RULING: (The Court used its earlier ruling in the earlier case regarding the same portion of land)
Evidently, the litigated area was forestal land. The fact that Datu Julian Bagobo and the other occupants had to make kaingin
in order to clear the lots is certainly indicative of the forestal nature of the same. Datu Julian Bagobo and his predecessors who
claimed possession over the area did not and could not have acquired ownership over the said land considering that the same
was then inalienable and non- disposable. It remained so for many years. In fact, it was only on February 4, 1956 when the
contested portions of the public domain were declared and classified as alienable and disposable per Forestry Administrative
Order No. 4-480 issued by the then Secretary of Agriculture and Natural Resources.
Respondent Zartiga knew that he could not directly acquire the lots since they were part of the public domain. So, he had to
get access to the land indirectly. He also realized that the indirect way was Datu Julian Bagobo who claimed possession over
the area. He had to clothe the datu with a color of ownership so that the latter could subsequently transfer the land to him.
Respondent accomplished this in a haphazard manner — by railroading the issuance of a tax declaration to the uneducated
datu and manipulating the alleged sale within the same day. This explains why there could not be sufficient and concrete
evidence of the alleged deed of sale, why the contested lots could never be accurately identified (boundaries were not
uniformly identified) and why private respondent never raised a hand when the townsite of Bansalan was being developed.

Forestal Lands are part of public domain which makes them unregistrable.

2
3