ASTROLOGIO, JERIC L.

CERVANTES, KATE PANDORA

NATIVIDAD, ARLENE M.

Mateo vs Insular Government Case

GR No. L-2746
December 6, 1906

FACTS OF THE CASE

 On June 23, 1903, Mateo Cariňo went to the Court of Land Registration to petition his
inscription as the owner of a 146 hectare land he’s been possessing in the then
municipality of Baguio. 
 Mateo Cariño Is an Igorot of the province of Benguet for the land lies, field for writ of
error.
 For more than 50 years before the Treaty of Paris, April 11 1899, he and his grandfather
had lived upon it and had maintained fence sufficient for the holding of cattle. His father
had cultivated parts and had used parts for pasturing cattle, and he had used it for pasture
in his turn. They all had been recognized as owners by the Igorot and he inherited or
received the land from his father in accordance with the Igorot custom.
 He applied for registration of certain land and there was no document of title issued for
the land at the time of registration.
 The government contends that the land in question belonged to the state. Under the
Spanish law, all lands belong to the Spanish Crown except those with permit private
titles.
 1893-1894 & 1896 -1897; He made an application but with no avail.
 1901; the plaintiff filed a petition alleging ownership, under the mortgage law, and the
lands were registered to him, however, that process only established possessory title.
 Even if the applicant has title, you cannot have it registered, because the Philippine
Commission’s Act no. 926 of 1903, except the province of Benguet among others from
its operation.

BONE OF CONTENTION
  Whether or not Cariño is the rightful owner of the land by virtue of his possession for
some time and entitled to registration.

SUPREME COURT DECISION

In the case provided, it is stated that Cariño’s petition for the ownership of land has been
approved by the Court of Land Registration yet with the opposition of the Philippine
Government and the US Government, was later on dismissed. The Philippine government
contested that despite the length of years of occupancy by the native group of the petitioner, it is
not enough justification for him to be entitled of ownership since the Igorot’s inability of being
held under colonial control has made them ignorant of the prevailing laws and statutes on land
and others (from the pre- to post-Spanish era). Their lack of knowledge on these laws have made
them incapable of securing their interests through legal means that should be regarded in terms
of grants, adjustments, etc.
As for the US government, they argue that the lack of proof of possession, whether by grant or
other lawful means does not merit Cariño ownership. With the plaintiff’s failure to present a
documentary evidence of title, a retrospective view of their ownership (even as an agricultural
land) fails to exist.

PONENTE
 OLIVER WENDELL HOLMES