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Land, Titles, and Deeds

I.
Land Registration in the Philippines
A.
History
1521 –1898 (Spanish Colonization)-‐Introduce the Regalian Doctrine.

All lands of the public domain, waters, minerals, coal, petroleum, and other
mineral oils, all forces of potential
energy, fisheries, forests or timber, wildlife, flora and fauna, and other
natural resources are owned by the State. With the
exception of agricultural lands, all other natural resources shall not be
alienated.”
–Art. XII, Sec. 2 of the 1987 Constitution
Regalian Doctrine was introduced in the Law of Lands (?)
1.Spanish Mortgage Law –registration of Titles
2.Maura Law –compulsory registration
Under US Colonization
Philippine Commonwealth acts as legislative body in the Philippines
Philippine Bill of 1902
a.
All land is placed under the Government of the Philippines
b.
Allows the government to enact laws disposing public lands (e.g. sales of
public lands (?), judicial confirmation of title)
Laws Enacted under the Philippine Bill of 1902:
1.
Land Registration Law
(Act No. 496, February 1, 1903
)
a.
Torrens System
“A system for registration of land under which, upon the landowner’s
application, the court may, after appropriate
proceedings, direct the issuance of a certificate of title.”
“Generally, the Torrens system refers to the system of registration
transactions (?) with interest in land whose object is, under governmental
authority, to establish and certify to the ownership of an absolute and
indefeasible
title to reality, and to simplify its transfer.”

as the schem
e in registration of land

named after Sir Robert Torrens (1857)

Register of Deeds
(ROD)
b.
Allowed the Judicial Confirmation of Imperfect Title (JCIT)
c.
Created the Court of Land Registration and Registry of Deeds
2.
First Public Land Act
(Act No. 926,
October 7,
1903)
“Voluntary Registration”
a.
Allowed judicial and administrative confirmation of imperfect title
b.
Introduced homestead patent
c.
Sale and Lease
3.
Cadastral Law (Act No. 2259,
February 13, 1913)
“It is a compulsory registration of lands initiated by the
government”
4.
Act No. 2347
, July 1914
“It created the Court of First Instance (CFI) and General Land
Registration Office (GLRO), which, under it, is the
Registry of Deeds (ROD)
5.
Second Public Land Act (Act No. 2847, 1919)
“It limited the registration to Filip
ino Citizens and Agricultural Lands”
Laws Enacted under the 1935 Constitution:
1.
Public Land Act (Act No. 441, December 1, 1936)
“It is the general law to be applied in the registration of land.
2.
RA 1151, 1957
“Abolished GLRO and created the Land Registratio
n Commission (LRC)
3.
PD 892, 1976
“Disallowed the use of Spanish Title as evidence of ownership.”
4.
Property Registration Decree (PD 1529, June 11, 1978)
“Original Land Registration Decree (OLR)
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Land,
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Limitation: can only acquire up to 5000 sq. m in urban areas and 3
hecatres in rural areas for commercial and
ind
ustrial; and 1000 sq. m in urban areas and 1 hectare in rural areas for
residential.
b.
Succession

compulsory heir
c.
Aliens who has acquired the land before the effectivity of the 1935
constitution
(Nov. 15 (?), 1935)
d.
Aliens who were Filipino at the time of a
cquisition
3.
Private Corporations or Associations
a.
Those which acquired lands, formerly part of the alienable and
disposable lands of public domain, from
Filipino Citizens who had possessed the same in the
manner and or the length of time indicated therein
b.
Th
ose which acquired the lands before the effectivity of the 1973 constitution
(Oct. 16, 17, 18 (?), 1973)
-‐
the constitutional prohibition do not apply to public lands already
converted into private ownership by natural
persons under the provisions of the Pub
lic Act.
-‐
Technically, the private corporation will just resell the property to Filipino
citizens for registration then back to the
corporation.
Non
-‐
Resident Applicant. If the applicant is not a resident of the Philippines, he
shall file with his
application an instrument in
due form appointing an agent or representative residing in the Philippines,
giving his full name and postal address, and shal
l
therein agree that the service of any legal process in the proceedings
under or growing out of the a
pplication made upon his
agent or representative shall be of the same legal effect as if made
upon the applicant with the Philippines, the applicant s
hall
forthwith make another appointment for the substitute, and, if he fails to
do so, the court may dismi
ss the application.
Reclaimed Lands. It does not automatically become alienable and disposable;
there must be first an express classification fro
m
the government.
Exception: if a private individual or entity who conducted the reclamation
under BOT (build,
operate, transfer) contract, the
property becomes a patrimonial property of the state.
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Cadastral Proceedings
It is a compulsory registration of lands initiated by the government. It is
when in the opinion of the President of the Phili
ppines
that public
interest so requires that title to any unregistered lands be settled and
adjudicated.
2.
Jurisdiction
A.
Exclusive Jurisdiction
Regional Trial Court (RTC) have exclusive jurisdiction over all applications
for original registration of title to lands,
including
improvements and interests therein, and over all petitions filed after original
registration of title, with
power to hear and determine all questions arising upon such applications
or petitions. (PD 1529)
B.
Delegated Jurisdiction
MeTc, MTC, and MCTC may be
assigned by the SC to hear and determine cadastral and land registration
cases
covering lots where:
a.
There is no controversy or opposition or contested lots
b.
The value of land does not exceed P100000.00 (BP 129 Judiciary
Reorganization Act of 1980 as amended
by
RA 7691)
3.
Procedure from filing of application until judgment
Petition must be notarized
As provided
in Sec. 15 of PD 1529, the application for land registration shall be in
writing, signed by the applicant or the
person duly authorized in his behalf, and sworn to before any officer
authorized to administer oaths for the province or city
where the applic
ation was actually signed. If there is more than one applicant, the
application shall be signed and sworn to by
and in behalf of each.
Document as annexes
1.
SURVEY PLAN it may be on tracing cloth, blue print, or white print as
long as it is a clear, convin
cing, and strong
evidence
2.
TECHNICAL DESCRIPTION OF LOT duly certified by the Regional Technical
Director (RTD)
3.
Certificate from geodetic engineers
4.
Tax declaration or certificate of assessment
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Land,
Titles, and Deeds
5.
Muniments of title
Notice of initial hearing
OLR/JCIT
(Volunta
ry)
CADASTRAL
(Involuntary, Government Initiates)
PD 1529 Section 23. Notice of initial hearing,
publication, etc.
The Court shall, within 5 days from filing of the
application, issue an order setting the date and
hour of the initial hearing which shall
not be
earlier than forty
-‐
five days nor later than
ninety days from the date of the order.
The public shall be given notice of the initial
hearing of the application for land registration
by means of (1) publication; (2) mailing; and
(3) posting.
1.
By publ
ication
Upon receipt of the order of the court
setting the time for initial hearing, the
Commissioner of Land Registration
shall cause notice of initial hearing to
be published once in the official
gazette and once in a newspaper of
general circulation in
the Philippines:
Provided, however, that the
publication in the official gazette shall
be sufficient to confer jurisdiction
upon the court.
Act No. 2259. The notice of initial hearing is
addressed to all individual person appearing to
have an interest in t
he lands involved and the
adjoining owners so far as known, and to all
whom it may concern.
Absent specific provisions in PD 1529
governing notice of the initial hearing of the
petition in Cadastral proceedings, the pertinent
provisions of the Cadastral A
ct, which are not
inconsistent with said decree, should be
applied.
1.
By publication
Sec.7. Upon receipt of the order of the
court setting the time for initial
hearing of the petition of the
Administrator of the LRA shall cause
notice thereof to be publishe
d twice, in
successive issues of the official
gazette, in English language.
Purpose of publication:
a.
to confer jurisdiction over the land applied for upon the court, and
b.
to charge the whole world with knowledge of the application of the land
involved, and
invite them to take part in the case and assert and prove their rights
over the property
subject thereof.
Publication over bigger lot:
as if no publication at all and it confers no jurisdiction over the
court
;
Publication over smaller lot:
it confers
jurisdiction only up to the smaller lot published.
Exception:
Bonin Case

wherein the unpublished lot is immaterial therefore the court acquires
jurisdiction even to the unpublished area.
2.
By mailing
a.
Mailing of notice to persons named in the application.
The commissioner of LRA shall also, within 7 days after publication of
said notice in
the official gazette, as hereinbefore provided, cause a copy of the
notice of initial
hearing to be mailed to every person named in the notice whose address
is known.
b.
Mai
ling of notice to the secr
etary of public highways, the provincial governor,
and
the mayor
.
If the applicant requests to have the line of a public way or road
determined, the
Commissioner of LRA shall cause a copy of said notice of initial hearing
to be ma
iled
to the secretary of public highways, to the provincial governor, and to the
mayor of
the municipality or city, as the case may be, in which the land lies.
c.
Mailing of notice to the secretary of agrarian reform, the solicitor
general, the
director of la
nds, the director of public works, the director of forest development,
the
director of mines, and the director of fisheries and aquatic resources.
If the land borders on a river, navigable stream or shore, or on an arm
of the sea
where a river or harbor li
ne has been established, or on a lake, or if otherwise
appears from the application or the proceedings that a tenant
-‐
farmer or the national
government may have a claim adverse to that of the applicant, notice of
the initial
hearing shall be given in the sa
me manner to the secretary of agrarian reform, the
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Land,
Titles, and Deeds
solicitor general, the director of lands, the director of mines, and/or the
director of
fisheries and aquatic resources, as may be appropriate.
3.
By posting
The commissioner of LRA shall also cause a duly a
ttested copy of the notice of initial
hearing to be posted by the sheriff of the province or city, as the case
may be, or by his
deputy, in a conspicuous place on each parcel of land included in the
application and also
in a conspicuous place on the bullet
in board of the municipal building of the
municipality or city in which the land or portion thereof is situated,
14 days at least
before the date of initial hearing.
The court may also case notice to be served to such other persons and
in such manner as
it
may deem proper.
PD 1529 Section 24. Proof of publication and notice.
The certification of the commissioner of LRA (now administrator of LRA;
ALRA) and of the sheriff concerned to the effect that
the notice of initial hearing, as required by law, has
been complied with shall be filed in the case before the date of initial
hearing, and shall be conclusive proof of such fact.
Proof of Publication

certification from ALRA
Proof of Mailing

certification from ALRA; and
Proof of Posting

certification
from sheriff.
Exception
: Such certification cannot, however, be conclusive proof of the fact of
publication and/or posting, if the certification
is made even:
1.
Prior to the actual publication of the notice or release for circulation of
the official gazett
e; or
2.
Prior to the completion of the 14
-‐
day period of actual posting of such notice.
PD 1529 Section 19. Amendments.
Amendments to the application including _____________ substitution, or
discontinuance as to parties may be allowed by the cou
rt
at any sta
ge of the proceedings upon just and reasonable terms.
Amendments,
which shall consist in a substantial change in the boundaries or an
increase in area of the land applied for or
which involve the
inclusion of an additional land,
shall be subject to the sa
me requirements of publication and notice as in an
original application.
Amendment
can be made at any stage.
Requirement of republish in order for the court to acquire jurisdiction in 3
instances:
1.
Substantial change in boundaries
2.
Increase in area
3.
Additional land
Opposition to application in ordinary proceedings
The interested party to the land subject of registration may file his
opposition to the application on or before the date
of initial hearing.
It must be a verified opposition. However,
failure to verify said pleading is not sufficient to divest the party from his
standing in court. The court, instead of dismissing his opposition outright,
may allow the oppositor to verify his opposition
.
Sec.25 of PD 1529 provides:
Any person claiming a
n interest, whether named in the notice or not, may appear and file an
opposition on or before the date
of initial hearing, or within such further time as may be allowed by the
court. The opposition shall state all the objections
to
the application and sha
ll set forth the interest claimed by the party filing the same and apply
for the remedy desired, and shall
be signed and sworn to by him or by some other duly authorized
person.
If the opposition or the adverse claim of any person cover only a portion
of
the lot and said portion is not properly delimited
on the plan attached to the application, or in case of undivided co
-‐
ownership, conflicting claims of ownership or possession, or
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Land,
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overlapping of boundaries, the court may require the parties to submit a
sub
division plan duly approved by the director of
lands.
The oppositors
The oppositor to an application for registration may not be named in the
notice of initial hearing. He must claim an
interest to the property applied for, based on a right of dominion o
r some other real right independent of, and not at all
subordinate to, the right of the government. The oppositor does not have
to show title in himself; he should, however, appear
to have an interest in the property.
Contents and Form of Opposition
The
opposition shall state:
1.
All the objections to the application
2.
Set forth the interest claimed by the oppositor
3.
Duly signed and sworn to by him or by his duly authorized representative
Declaration of default

General Default
Absent any oppositor, the court
will issue an order of default pursuant to Sec. 26 of PD 1529 which
reads:
If no person appears and answers within the time allowed, the court shall,
upon motion of the applicant, no reason to
the contrary appearing, order a default to be recorded and requ
ire the applicant to present evidence. By the
description in the notice, “To all whom it may concern”
, all the world are made parties defendant and shall be
concluded by the default order.
Where an appearance has been entered and an answer filed, a defau
lt order shall be entered against persons who did
not appear and answer.

Special Default
It is where an oppositor has already filed with the court an opposition
based on substantial grounds but failed to
appear in the initial hearing. It is improper, even
illegal, to declare him in default simply because he failed to appear at
the initial hearing.
Motion to dismiss opposition
It is based on the following:
1.
Lack of jurisdiction
2.
Res judicata
Hearing/Trial
The parties are:
1.
Applicant
2.
Oppositor
3.
Government
Who has the burden of proof?
The applicant must show incontrovertible evidence.
He must prove:
(a)
That
the land applied for has been declassified from the forest or timber zone
and is a public agricultural land, is
alienable and disposable, or otherwise capab
le of registration;
(b)
Identity of land;
(c)
His possession and occupation thereof for the length of time and in the
manner required by law;
(d)
The basis of such claim by submitting his muniments of title or whatever
evidence to support the same, if he claims
privat
e ownership not because of his possession.
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Land,
Titles, and Deeds
Specific Evidence
A.
Proofs that the land has been declassified from the forest zone, is
alienable or disposable, and is registrable.
1.
Presidential proclamation;
2.
Executive order;
3.
Administrative order issued by S
ecretary of DENR;
4.
BFD Land Classification Map;
5.
Certification by the Director of Forestry; and reports of district Forester;
6.
Investigation reports of Bureau of Lands investigator;
7.
Legislative act or by statute.
B.
Proofs of Identity of Land
1.
Survey plan in
general;
2.
Tracing cloth plan and blue print copies plan;
3.
Technical description of land applied for, duly signed by Geodetic Engineer;
4.
Tax declaration;
5.
Boundaries and area.
C.
Proofs of Private Ownership
1.
Spanish titles, in pending cases;
2.
Tax declaration and
realty tax payments;
3.
Presidential issuances and legislative acts;
4.
Other kinds of proof, like, testimonial evidence and deeds of sale.
Section 27. Speedy hearing; reference to a referee.
The trial court shall see to it that all registration
-‐
proceedings are
disposed of within 90 days from the date the case is
submitted for decision.
The court, if it deems necessary, may refer the case or any part
thereof to a referee who shall hear the parties and their
evidence, and the referee shall submit his report ther
eon to the Court within 15 days after the termination of such hearing.
Hearing before a referee may be held at any convenient place within the
province or city as may be fixed by him and after
reasonable notice thereof shall have been served the parties co
ncerned. The court may render judgment in accordance with
the report as though the facts have been found by the judge himself:
provided, however, that the court may in its discretion
accept the report, or set it aside in whole or in part, or order the
case
to be recommitted for further proceedings.
Judgment
It was provided for in PD 1529 that:
Section 28. Partial judgment. In a case where only a portion of the land
subject of registration is contested, the court may
render partial judgment provided that
a subdivision plan showing the contested and uncontested portions approved
by the
Director of Lands is previously submitted to said court.
Section 29. Judgment confirming title.
All conflicting claims of ownership and interest in the land subject of the
a
pplication shall be determined by the court. If the
court, after considering the evidence and the reports of the Commissioner
of LRA and the director of lands, finds that the
applicant or the oppositor has sufficient title proper for registration, judgment
shall be rendered confirming the title of the
applicant, or the oppositor, to the land or portions thereof.
Finality of judgment and order to issue decree
Section 30. When judgment becomes final; duty to cause issuance of
decree.
The judgment rendered i
n a land registration proceedings becomes final upon the expiration of 30
days to be counted from the
date of receipt of notice of the judgment. An appeal may be taken from
the judgment of the court as in ordinary civil cases.
(The finality of judgment as
above provided by the decree has been modified to the lapse of 15
days counted from receipt of
the notice of judgment; as provided for by PB? 129)
After judgment has become final and executor, it shall devolve upon the
court to forthwith issue an order in
accordance with
section 39 of this decree to the commissioner for the issuance of the
decree of registration and the corresponding certificat
e of
title in favor of the person adjudged entitled to registration.
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Land,
Titles, and Deeds
Period of appeal
The period of appeal shall
be reckoned from receipt of the decision, within 15 days before the
judgment becomes final. Receipt
of judgment by solicitor general, not by fiscal, binds the government.
Example:
Date of Receipt
Judgment becomes final
Applicant
Jan. 1
Jan. 17
Oppositor
Jan. 8
Jan. 24
SolGen
Jan. 15
Jan. 31

Notwithstanding the lapse of the 15 day period from receipt of judgment
by the parties, the court continues to retrain
control of the case until the expiration of 1 year after the entry of
decree of regist
ration by the LRA.
Whether or not res judicata will apply?

In OLR, res judicata will apply.

In JCIT, res judicata will NOT apply.
Remedies
An aggrieved party may take any of the remedies available in law to
challenge the judgment in a land registration
case or the
validity of title issued pursuant thereto.
Before the judgment becomes final
1.
Motion for reconsideration
Ground: error committed by the court in interpreting the facts of the case
and the law.
2.
New trial
Grounds:
a.
fraud, accident, mistake, or e
xcusable negligence which ordinary prudence could not have guarded against
and by
reason of which such aggrieved party has probably been impaired of his
rights;
b.
newly discovered evidence, which he could not, with reasonable diligence,
have discovered, and
produced at the
trial and which, if presented, would probably alter the result;
c.
award or excessive damages, or insufficiency of the evidence to justify the
decision or that the decision is against
the law.
After rendering judgment but before judgment beco
mes final
3.
Appeal
Laws applicable are PD 1529 and Rule 41, 45, and 65 of Rules of
Court
Appeal to the Court of Appeals is taken by simply filing a notice of
appeal with the lower court within 15 days from
receipt of said judgment of order by counsel of t
he aggrieved party. However, appeals to the appellate court in the
exercise of its appellate jurisdiction are by petition for review. And petition
for certiorari under rule 65 on the ground
of grave abuse of discretion amount to lack or excess of jurisdict
ion.
Example:
Jan. 1, 2011
Jan. 14, 2011
Feb. 5, 2011
Date of receipt
Motion for reconsideration
or New Trial
Denial of MR/NT,
Date of order
Another 15 days period to
perfect an appeal (fresh
period)
4.
Relief from judgment
Grounds: when a judgment or
order is entered, or other proceedings is taken against a party in RTC
through fraud,
accident, mistake, or excusable negligence, a party may file a petition in
such court and in the same cause praying that
the judgment, order or proceeding be set aside.
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Land,
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The petition must be verified and filed within 60 days after the petitioner
learns (receipt) the judgment, order, or
other proceeding, and not more than 6 months after such judgment or
order was entered or such proceeding was
taken.
Only a party that is
either the applicant or the oppositor may avail of the remedy.
5.
Annulment (Rule 47 of Rules of Court)
Grounds: extrinsic fraud and lack of jurisdiction

Other remedies are no longer available.
6.
Petition for review
A petition for review must be filed not
later than 1 year from and after the date of the entry of such
decree of
registration. Unless, upon the expiration of said period of 1 year, the
decree of registration and certificate of title shall
become incontrovertible.
Limitation: well in no case sha
ll such petition be entertained by the court where an innocent purchaser
for value or
buyer in good faith has acquired the land or an interest therein, whose
rights may be prejudiced.
Who may file a petition?
Any person who were deprived of their opportun
ity to be heard in the original land registration.
Essential requisites for the reopening or review decree:
1.
Petitioner has a real and dominical right;
2.
He has been deprived thereof;
3.
Through fraud;
4.
Petition is filed within 1 year from issuance of the decree
and in respect to a review of the judgment, from
rendition thereof; and
5.
The property has not yet passed to an innocent purchaser for value.
Writ of Possession

It is a mere post
-‐
judgment ________ _________ adjudicating ownership to a successful applicant
impliedly carries
with it the delivery of possession if he is deprived thereof because the
right of possession is inherent to right
of ownership.

A motion for writ of possession may be filed by the winning party.

The sheriff, upon the order of the court,
shall implement the writ of possession for the eviction of any person
in the property.

Limitation: it is a settled rule that when parties against whom a writ of
possession is sought have been in
possession of the land for at least 10 years, and they entere
d into possession apparently after the issuance of
the final decree, and none of them had been a party in the registration
proceedings, the writ of possession will
not issue.

Reason for the limitation: because they cannot be ousted without giving
them thei
r day in court in proper
independent proceedings.

Proper remedy of the successful applicant: a separate action for
unlawful detainer or entry, or for
reivindicatory action, as the case may be.

When there is refusal to vacate the property despite the writ,
the proper remedy is for the sheriff who
implemented the writ to avail himself of the public force (resorting help
from police or tanod), had it been
necessary to resort thereto.

If subsequent to such dispossession or ejectment, the losing party “enters”
o
r attempts to enter into or upon
the property, then and only then may be the loser be charged with and
punished for contempt.

Writ of demolition is against the property. It is a consequence of writ of
possession.
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Decree of Registration
It is pur
suant to the order of the court that the LRA prepares and issues a
decree of registration. 1 year after the
decree has been entered in the books of registry, it becomes
incontrovertible or indefeasible.
Duty of the administrator of LRA to issue decree
T
he duty of the land registration officials to issue the decree of registration
is ministerial in the sense that they act
under the orders of the court and the decree must be in conformity with
the court judgment
and with the date found in the
record. They
have no discretion.
However, if they are in doubt upon any point in relation to the
preparation and issuance of the decree or if there was
an apparent mistake or error that can invalidate the title, they are duty
bound to refer the matter to the court. Th
ey act in this
respect as court officials and not as administrative officials.
The administrator is thus not legally obligated to issue the decree where
he finds that subject land has already been
decreed and titled in another’s name. And he could not be
compelled through mandamus because the issuance of the decree is
part of the judicial function of courts and not a mere ministered act.
General Rule: The decree becomes incontrovertible or indefeasible after
the lapse of 1 year from the date of entry and
it
cannot be attacked. It may be set as a defense.
Exception:
a.
when there is a previous valid title;
b.
non
-‐
registrable land;
c.
expanded area;
Situations where a person cannot invoke the incontrovertibility of the decree:
a.
action for reconveyance, it is when ano
ther person has registered the property through fraud or mistake giving rise
to
implied trust;
b.
validity of TCT.
B. Administrative Mode
Land Patents: Kinds
???
Homestead Patent
Free Patent
Sales Patent
Residential, industrial,
?
?
With bidding
Without bidding RA
730, June 30, 1952
Citizenship
Any Filipino
Natural Born Filipino
Citizen
Any Filipino Citizen
Any Filipino Citizen
Age
Over the age of 18, or
head of the family?
Lawful age
Head of the family
Over 18 years old
Land ownership
Does
not own more than
12 hectares of land in
the Philippines or has
not had the benefit of
any gratuitous allotment
of more than 12
hectares of land since
the occupation of the
Philippines by the US
Does not own more
than 12 hectares of
land
Purchase agricultu
ral
land
Not owner of a home
lot in the municipality
in which he resides
Residence
Resided continuously
for at least one year in
the municipality where
the land is situated
At least 30 years (at
least from March 8,
1960) prior to the
effectivity of this
a
mendatory act
(March 28, 1990), has
“continuously” COC?
None
Who has in good faith
established his
residence on parcel of
land of the public
domain of RP which is
not needed for public
service
Cultivation
Must have “cultivated”
at least 1/5 of the land
“occupied” and
cultivated, either by
1.
If agricultural
land:
Agricultural: 1/5
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a
pplied for
himself or through his
P
-‐
I
-‐
N a tract of
agricultural public
land subject to
disposition, who shall
have paid realty tax
thereon
Required to
have at least
1/5 of the
land broken
and culti
vated
within 5 years
from the date
of award
2.
If for
residential,
commercial,
industrial:
“after” he
shall have
completed the
construction
of permanent
improvement
s appropriate
for the
purpose for
which the
land is
purchased
within 18
months from
the date of
award
Limitation in area
12 hectares
12 hectares
12 hectares
1000 sq.m.
restrictions
1.
Not subject to
encumbrance
or disposition
within 5 years
from the date
of issuance. The
patent
is
deemed issued
upon
the
promulgation
of the order
for
issuance
thereof by the
Director
of
Lands.
Limitation: except in
favor of the:
a.
government
b.
or

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