Carino v. Insular Government, 212 U.S.

449 (1909)

Facts:

 Carino is an Igorot from Benguet. He claims ownership over the land in question as far back as
50 years through his ancestors and even before the Treaty of Paris. According to him, he
received the land in question from his forefathers by custom but no document of title was
issued by the Spanish Crown.
 In 1901, he filed a petition alleging ownership under the Mortgage Law, and the lands were
registered to him via a possessory title.
 The Philippine Government, however, also on behalf of the United States filed an appeal to
question Carino’s possession of the land. The government claimed that those were government
lands given that they have already taken possession of the property for public and military
purposes.
 The Court of First Instance dismissed Carino’s application. The SC affirmed the CFI’s decision.

Issue: WON Carino owns the land in question.

Held: Yes.

 Government’s basis for claiming ownership:

o Spain’s assertion that it had title to all the land in the Philippines would carry over to the
United States as the new colonizer of the Philippines.
o Carino did not meet the period of required registration to validate private ownership.
 Court’s Decision:
o According to the Court, the decrees and laws cited by the Government of the
Philippines, in fact, indicate that natives were recognized as owning lands irrespective of
any royal grant if they privately own the land via ancient possession. (“Where such
possessors shall not be able to produce title deeds, it shall be sufficient if they shall
show that ancient possession as a valid title by prescription.”)
o Period of required registration is not applicable to those already declared as owners
such as Carino.