REBUPLIC VS CA (G.R. NO.

144057)
Facts:
Corazon Naguit filed with the MCTC of Ibajay-Nabas, Aklan, a petition for registration of title of a
parcel of land situated in Brgy. Union, Nabas, Aklan. The application seeks judicial confirmation of
respondent’s imperfect title over the aforesaid land.
The public prosecutor, appearing for the government, and Jose Angeles, representing the heirs of
Rustico Angeles, opposed the petition. The evidence on record reveals that the subject parcel of
land was originally declared for taxation purposes in the name of Ramon Urbano (Urbano) in 1945
until 1991.
On July 9, 1992, Urbano executed a Deed of Quitclaim in favor of the heirs of Honorato Maming
(Maming), wherein he renounced all his rights to the subject property and confirmed the sale made
by his father to Maming sometime in 1955 or 1956. The heirs of Maming executed a deed of absolute
sale in favor of respondent Naguit who thereupon started occupying the same. Naguit and her
predecessors-in-interest have occupied the land openly and in the concept of owner without any
objection from any private person or even the government until she filed her application for
registration.
MCTC rendered a decision ordering that the subject parcel be brought under the operation of the
Property Registration Decree or Presidential Decree (P.D.) No. 1529 and that the title thereto
registered and confirmed in the name of Naguit.
The Office of the Solicitor General (OSG), filed a motion for reconsideration. The OSG stressed that
the land applied for was declared alienable and disposable only on October 15, 1980. MCTC denied
the motion for reconsideration. RTC dismissed the appeal made by the Republic. CA affirmed in toto
the assailed decision of the RTC.
Issue:
Whether or not there is no need for the government’s prior release of the subject lot from the public
domain before it can be considered alienable or disposable within the meaning of P.D. No. 1529.
Held:
Yes. This reading aligns conformably with our holding in Republic v. Court of Appeals [G.R. No.
127060, 19 November 2002, 392 SCRA 190.] . Therein, the Court noted that "to prove that the land
subject of an application for registration is alienable, an applicant must establish the existence of a
positive act of the government such as a presidential proclamation or an executive order; an
administrative action; investigation reports of Bureau of Lands investigators; and a legislative act or
a statute."15 In that case, the subject land had been certified by the DENR as alienable and
disposable in 1980, thus the Court concluded that the alienable status of the land, compounded by
the established fact that therein respondents had occupied the land even before 1927, sufficed to
allow the application for registration of the said property. In the case at bar, even the petitioner
admits that the subject property was released and certified as within alienable and disposable zone
in 1980 by the DENR.
Prescription is one of the modes of acquiring ownership under the Civil Code. There is a consistent
jurisprudential rule that properties classified as alienable public land may be converted into private
property by reason of open, continuous and exclusive possession of at least thirty (30) years. With
such conversion, such property may now fall within the contemplation of "private lands" under
Section 14(2), and thus susceptible to registration by those who have acquired ownership through
prescription. Thus, even if possession of the alienable public land commenced on a date later than
June 12, 1945, and such possession being been open, continuous and exclusive, then the
possessor may have the right to register the land by virtue of Section 14(2) of the Property
Registration Decree.
 HON. HEHERSON T. ALVAREZ v. PICOP RESOURCES, INC.G.R. No. 162243,
December 3, 2009
Doctrine: A timber license is not a contract within the purview of the non-impairment
clause.

Facts
PICOP filed with the DENR an application to have its Timber License Agreement
(TLA) No. 43converted into an IFMA.PICOP filed before the (RTC) City a Petition for
Mandamus against then DENR Sec Alvarez for unlawfully refusing and/or neglecting
to sign and execute the IFMA contract of PICOP even as thelatter has complied with
all the legal requirements for the automatic conversion of TLA No. 43, asamended,
into an IFMA.The cause of action of PICOP Resources, Inc. (PICOP) in its Petition for
Mandamus with the trialcourt is clear: the government is bound by contract, a 1969
Document signed by then PresidentFerdinand Marcos, to enter into an Integrated
Forest Management Agreement (IFMA) with PICOP.

Issue
Whether the 1969 Document is a contract recognized under the non-impairment
clause by which thegovernment may be bound (for the issuance of the IFMA)

Held
NO. Our definitive ruling in Oposa v. Factoran that a timber license is not a contract
within the purviewof the non-impairment clause is edifying. We declared: Needless to
say, all licenses may thus berevoked or rescinded by executive action. It is not a
contract, property or a property right protected bythe due process clause of the
Constitution. Since timber licenses are not contracts, the non-impairment clause,
which reads: "SEC. 10. No lawimpairing the obligation of contracts shall be passed."
cannot be invoked.The Presidential W arranty cannot, in any manner, be construed
as a contractual undertaking assuringPICOP of exclusive possession and enjoyment
of its concession areas. Such an interpretation wouldresult in the complete abdication
by the State in favor of PICOP of the sovereign power to control andsupervise the
exploration, development and utilization of the natural resources in the area.
 HEIRS OF MARIO MALABANAN v. REPUBLIC G.R. No. 179987
FACTS
Mario Malabanan filed an application for land registration covering the property he
purchased from Eduardo Velazco, claiming that the property formed part of the
alienable and disposable land of the public domain, and that he and his predecessors-
in-interest had been in open, continuous, uninterrupted, public and adverse
possession and occupation of the land for more than 30 years, thereby entitling him
to the judicial confirmation of his title.
The application was granted by the RTC. However, the OSG for the Republic
appealed the judgment to the CA, which reversed the RTC Judgment. Due to
Malabanan’s intervening demise during the appeal in the CA, his heirs elevated the
said decision to this Court through a petition for review on certiorari. The petition was
denied. Petitioners and the Republic filed Motions for Reconsideration.
ISSUE
What are the classifications of public lands? Whether or not petitioners were able to
prove that the property was an alienable and disposable land of the public domain?
RULING
1. Classifications of land according to ownership.
Land, which is an immovable property, may be classified as either of public dominion
or of private ownership. Land is considered of public dominion if it either:
(a) is intended for public use; or
(b) belongs to the State, without being for public use, and is intended for some
public service or for the development of the national wealth.
Land belonging to the State that is not of such character, or although of such character
but no longer intended for public use or for public service forms part of the patrimonial
property of the State. Land that is other than part of the patrimonial property of the
State, provinces, cities and municipalities is of private ownership if it belongs to a
private individual.
Pursuant to the Regalian Doctrine (Jura Regalia), a legal concept first introduced into
the country from the West by Spain through the Laws of the Indies and the Royal
Cedulas, all lands of the public domain belong to the State. This means that the State
is the source of any asserted right to ownership of land, and is charged with the
conservation of such patrimony.
All lands not appearing to be clearly under private ownership are presumed to belong
to the State. Also, public lands remain part of the inalienable land of the public domain
unless the State is shown to have reclassified or alienated them to private persons.
A positive act of the Government is necessary to enable such reclassification, and the
exclusive prerogative to classify public lands under existing laws is vested in the
Executive Department, not in the courts. If, however, public land will be classified as
neither agricultural, forest or timber, mineral or national park, or when public land is
no longer intended for public service or for the development of the national wealth,
thereby effectively removing the land from the ambit of public dominion, a declaration
of such conversion must be made in the form of a law duly enacted by Congress or
by a Presidential proclamation in cases where the President is duly authorized by law
to that effect. Thus, until the Executive Department exercises its prerogative to classify
or reclassify lands, or until Congress or the President declares that the State no longer
intends the land to be used for public service or for the development of national wealth,
the Regalian Doctrine is applicable.
2. Petitioners failed to present sufficient evidence to establish that they and their
predecessors-in-interest had been in possession of the land since June 12, 1945.
Without satisfying the requisite character and period of possession – possession and
occupation that is open, continuous, exclusive, and notorious since June 12, 1945, or
earlier – the land cannot be considered ipso jure converted to private property even
upon the subsequent declaration of it as alienable and disposable.
Prescription never began to run against the State, such that the land has remained
ineligible for registration under Section 14(1) of the Property Registration Decree.
Likewise, the land continues to be ineligible for land registration under Section 14(2)
of the Property Registration Decree unless Congress enacts a law or the President
issues a proclamation declaring the land as no longer intended for public service or
for the development of the national wealth.
 CRUZ VS SECRETARY OF DENR, GR. NO. 135385, DEC. 6, 2000
FACTS:
Petitioners Isagani Cruz and Cesar Europa filed a suit for prohibition and mandamus
as citizens and taxpayers, assailing the constitutionality of certain provisions of
Republic Act No. 8371, otherwise known as the Indigenous People’s Rights Act of
1997 (IPRA) and its implementing rules and regulations (IRR). The petitioners assail
certain provisions of the IPRA and its IRR on the ground that these amount to an
unlawful deprivation of the State’s ownership over lands of the public domain as well
as minerals and other natural resources therein, in violation of the regalian doctrine
embodied in section 2, Article XII of the Constitution.
ISSUE:
Do the provisions of IPRA contravene the Constitution?
HELD:
No, the provisions of IPRA do not contravene the Constitution. Examining the IPRA,
there is nothing in the law that grants to the ICCs/IPs ownership over the natural
resources within their ancestral domain. Ownership over the natural resources in the
ancestral domains remains with the State and the rights granted by the IPRA to the
ICCs/IPs over the natural resources in their ancestral domains merely gives them, as
owners and occupants of the land on which the resources are found, the right to the
small scale utilization of these resources, and at the same time, a priority in their large
scale development and exploitation.
Additionally, ancestral lands and ancestral domains are not part of the lands of the
public domain. They are private lands and belong to the ICCs/IPs by native title, which
is a concept of private land title that existed irrespective of any royal grant from the
State. However, the right of ownership and possession by the ICCs/IPs of their
ancestral domains is a limited form of ownership and does not include the right to
alienate the same.
 LEGARDA VS. SALEEBY, G.R. NO. 8936, OCTOBER 2, 1915
FACTS
The plaintiffs and the defendant occupy, as owners, adjoining lots in the district of
Ermita in the city of Manila. There exists and has existed a number of years a stone
wall between the said lots. Said wall is located on the lot of the plaintiffs. The plaintiffs,
March 2, 1906, presented a petition in the Court of Land Registration for the
registration of their lot, which decreed that the title of the plaintiffs should be registered
and issued to them the original certificate provided for under the Torrens system. Said
registration and certificate included the wall.
Later the predecessor of the defendant presented a petition in the Court of Land
Registration for the registration of the lot now occupied by him. On March 25, 1912,
the court decreed the registration of said title and issued the original certificate
provided for under the Torrens system. The description of the lot given in the petition
of the defendant also included said wall.
On December 13, 1912 the plaintiffs discovered that the wall which had been included
in the certificate granted to them had also been included in the certificate granted to
the defendant .They immediately presented a petition in the Court of Land
Registration for an adjustment and correction of the error committed by including said
wall in the registered title of each of said parties.
The lower court however, without notice to the defendant, denied said petition upon
the theory that, during the pendency of the petition for the registration of the
defendant’s land, they failed to make any objection to the registration of said lot,
including the wall, in the name of the defendant.

ISSUE
Who is the owner of the wall and the land occupied by it?

HELD
The decision of the lower court is based upon the theory that the action for the
registration of the lot of the defendant was a judicial proceeding and that the judgment
or decree was binding upon all parties who did not appear and oppose it
Granting that theory to be correct one , then the same theory should be applied to the
defendant himself. Applying that theory to him, he had already lost whatever right he
had therein, by permitting the plaintiffs to have the same registered in their name,
more than six years before. Having thus lost hid right, may he be permitted to regain
it by simply including it in a petition for registration?
For the difficulty involved in the present case the Act (No. 496) provides for the
registration of titles under the Torrens system affords us no remedy. There is no
provision in said Act giving the parties relief under conditions like the present. There
is nothing in the Act which indicates who should be the owner of land which has been
registered in the name of two different persons.
We have decided, in case of double registration under the Land Registration Act, that
the owner of the earliest certificate is the owner of the land. May this rule be applied
to successive vendees of the owners of such certificates? Suppose that one or the
other of the parties, before the error is discovered, transfers his original certificate to
an “innocent purchaser.” The general rule is that the vendee of land has no greater
right, title, or interest than his vendor; that he acquires the right which his vendor had,
only. Under that rule the vendee of the earlier certificate would be the owner as
against the vendee of the owner of the later certificate.
It would be seen to a just and equitable rule, when two persons have acquired equal
rights in the same thing, to hold that the one who acquired it first and who has
complied with all the requirements of the law should be protected.
In view of our conclusions, above stated, the judgment of the lower court should be
and is hereby revoked. The record is hereby returned to the court now having and
exercising the jurisdiction heretofore exercised by the land court, with direction to
make such orders and decrees in the premises as may correct the error heretofore
made in including the land in the second original certificate issued in favor of the
predecessor of the appellee, as well as in all other duplicate certificates issued.
 SUSI VS. RAZON (G.R. NO. 24066, DECEMBER 9, 1925)
Facts
Nemesio Pinlac owned a land which he used as fish pond.
In 1880, he sold it to Apolonio Garcia and Basilio Mendoza for P12.
In 1899, they sold it to Valentin Susi for P12.
The possession and occupation of the land was in open, continuous, adverse and
public, without any interruption, except during the revolution, or disturbance.
In 1914, Director of Lands sold the land to Angela Razon. (The Director of Lands
alleged that the land in question was a property of the Government of the United
States under the administration and control of the Philippine Islands.)
Issue
Was the sale of the land by the Director of Lands to Angela Razon valid?
Ruling
No. When Angela Razon applied for the grant in her favor, Valentin Susi had already
acquired, by operation of law, not only a right to a grant, but a grant of the
Government, for it is not necessary that certificate of title should be issued in order
that said grant may be sanctioned by the courts, an application therefore is sufficient,
under the provisions of section 47 of Act No. 2874. If by a legal fiction, Valentin Susi
had acquired the land in question by a grant of the State, it had already ceased to be
the public domain and had become private property, at least by presumption, of
Valentin Susi, beyond the control of the Director of Lands. Consequently, in selling
the land in question to Angela Razon, the Director of Lands disposed of a land over
which he had no longer any title or control, and the sale thus made was void and of
no effect, and Angela Razon did not thereby acquire any right.
The land had already become, by operation of law, private property of the Valentin
Susi, who, there lacking only the judicial sanction of his title, has the right to bring an
action to recover possession thereof and hold it.
 G.R. NO. 75042 NOVEMBER 29, 1988 REPUBLIC OF THE PHILIPPINES, PETITIONER, VS.
INTERMEDIATE APPELLATE COURT, ROMAN CATHOLIC BISHOP OF LUCENA,
FACTS
Properties Involved:
Lots 1, 2, and 3 situated in Barrio Masin, Municipality of Candelaria, Quezon Province.
Lot 4 located in Barrio Bucal (Taguan), Municipality of Candelaria, Quezon Province.
On February 2, 1979, the Roman Catholic Bishop of Lucena filed an application for confirmation of
title for the aforementioned four parcels of land. However, the Solicitor-General (in behalf of the
Director of Lands and the Director of the Bureau of Forest Development) filed an opposition to this
application on April 20, 1979, citing that the Bishop of Lucena did not have an imperfect title or title
in fee simple to the parcels of land being applied for.
The Bishop of Lucena provided evidence that Lot 1 was acquired by the Roman Catholic Church
thru Rev. Father Raymundo Esquenet by purchase from the spouses Atanacio Yranso and Maria
Coronado on October 20, 1928, while Lot 2 was acquired by purchase from the spouses Benito
Maramot and Venancia Descaller on May 22, 1969.
The remaining portions of Lots 2 and 3 were already owned and possessed by the Roman Catholic
Church even prior to the survey of the said lots in 1928. Lot 3 was also used by the church as a
burial site since 1918. All 3 lots are declared for taxation purposes in the name of the Roman Catholic
Church as a cemetery site. The fourth lot was acquired by donation from the spouses Paulo G.
Macasaet, and Gabriela V. de Macasaet on February 26, 1941. A new chapel stands on this lot.
The Bishop of Lucena has been in continuous possession and enjoyment of Lots 1, 2, and 3 for a
period of more than 52 years through its predecessors-in-interest, and a total of 39 years with
respect to Lot 4.
The Solicitor-General did not adduce evidence to support its opposition. When the case was
submitted, the lower court ordered the registration of the lands together with the improvements
thereon in the name of the ROMAN CATHOLIC BISHOP OF LUCENA.
On appeal, the Solicitor-General contends that the Bishop of Lucena is disqualified from owning
alienable lands from the public domain because the constitution prohibits a private corporation from
doing so.
ISSUE: Whether or not the Roman Catholic Bishop of Lucena, as a corporation sole, is qualified to
apply for confirmation of its title to the four (4) parcels of land.
RULING: Yes, the Roman Catholic Bishop of Lucena is qualified to apply for the confirmation of its
title to to the 4 parcels of land.
The acquired lots are already private lands upon acquisition of the church. Hence, the constitutional
prohibition does not apply anymore.
Sec. 113 Batas Pambansa Blg. 68 allows a corporation sole to purchase and hold real estate and
personal property for its church, charitable, benevolent or educational purposes, and may receive
bequests or gifts for such purposes. A corporation sole is a special form of corporation usually
associated with the clergy. It consists of one person only, and his successors (who will always be
one at a time) are incorporated by law in order to give them some legal capacities and advantages
which in their natural persons they could not have had.
The Bishop of Lucena has satisfactorily proved that they are in open, continuous, and exclusive
possession of the subject lots in the concept of owner.
The decision of the lower court is AFFIRMED.
 Roman Catholic Apostolic Administrator of Davao, Inc. v. The Land
Registration Commission and the Register of Deeds of Davao City, G.R. No. L-
8451, December 20,1957
TOPIC: Nationality of a corporation
Facts:
On October 4, 1954, Mateo L. Rodis, a Filipino citizen and resident of the City of
Davao, executed a deed of sale of a parcel of land located in the same city covered
by Transfer Certificate No. 2263, in favor of the Roman Catholic Apostolic
Administrator of Davao Inc.,(RCADI) is corporation sole organized and existing in
accordance with Philippine Laws, with Msgr. Clovis Thibault, a Canadian citizen, as
actual incumbent. Registry of Deeds Davao (RD) required RCADI to submit affidavit
declaring that 60% of its members were Filipino Citizens. As the RD entertained some
doubts as to the registerability of the deed of sale, the matter was referred to the Land
Registration Commissioner (LRC) en consulta for resolution. LRC hold that pursuant
to provisions of sections 1 and 5 of Article XII of the Philippine Constitution, RCADI is
not qualified to acquire land in the Philippines in the absence of proof that at leat 60%
of the capital, properties or assets of the RCADI is actually owned or controlled by
Filipino citizens. LRC also denied the registration of the Deed of Sale in the absence
of proof of compliance with such requisite. RCADI’s Motion for Reconsideration was
denied. Aggrieved, the latter filed a petition for mandamus.

Issue:
Whether or not the Universal Roman Catholic Apostolic Church in the Philippines, or
better still, the corporation sole named the Roman Catholic Apostolic Administrator of
Davao, Inc., is qualified to acquire private agricultural lands in the Philippines pursuant
to the provisions of Article XIII of the Constitution.

Ruling:
RCADI is qualified.
While it is true and We have to concede that in the profession of their faith, the Roman
Pontiff is the supreme head; that in the religious matters, in the exercise of their belief,
the Catholic congregation of the faithful throughout the world seeks the guidance and
direction of their Spiritual Father in the Vatican, yet it cannot be said that there is a
merger of personalities resultant therein. Neither can it be said that the political and
civil rights of the faithful, inherent or acquired under the laws of their country, are
affected by that relationship with the Pope. The fact that the Roman Catholic Church
in almost every country springs from that society that saw its beginning in Europe and
the fact that the clergy of this faith derive their authorities and receive orders from the
Holy See do not give or bestow the citizenship of the Pope upon these branches.
Citizenship is a political right which cannot be acquired by a sort of “radiation”. We
have to realize that although there is a fraternity among all the catholic countries and
the dioceses therein all over the globe, the universality that the word “catholic” implies,
merely characterize their faith, a uniformity in the practice and the interpretation of
their dogma and in the exercise of their belief, but certainly they are separate and
independent from one another in jurisdiction, governed by different laws under which
they are incorporated, and entirely independent on the others in the management and
ownership of their temporalities. To allow theory that the Roman Catholic Churches
all over the world follow the citizenship of their Supreme Head, the Pontifical Father,
would lead to the absurdity of finding the citizens of a country who embrace the
Catholic faith and become members of that religious society, likewise citizens of the
Vatican or of Italy. And this is more so if We consider that the Pope himself may be
an Italian or national of any other country of the world. The same thing be said with
regard to the nationality or citizenship of the corporation sole created under the laws
of the Philippines, which is not altered by the change of citizenship of the incumbent
bishops or head of said corporation sole.
We must therefore, declare that although a branch of the Universal Roman Catholic
Apostolic Church, every Roman Catholic Church in different countries, if it exercises
its mission and is lawfully incorporated in accordance with the laws of the country
where it is located, is considered an entity or person with all the rights and privileges
granted to such artificial being under the laws of that country, separate and distinct
from the personality of the Roman Pontiff or the Holy See, without prejudice to its
religious relations with the latter which are governed by the Canon Law or their rules
and regulations.
It has been shown before that: (1) the corporation sole, unlike the ordinary
corporations which are formed by no less than 5 incorporators, is composed of only
one persons, usually the head or bishop of the diocese, a unit which is not subject to
expansion for the purpose of determining any percentage whatsoever; (2) the
corporation sole is only the administrator and not the owner of the temporalities
located in the territory comprised by said corporation sole; (3) such temporalities are
administered for and on behalf of the faithful residing in the diocese or territory of the
corporation sole; and (4) the latter, as such, has no nationality and the citizenship of
the incumbent Ordinary has nothing to do with the operation, management or
administration of the corporation sole, nor effects the citizenship of the faithful
connected with their respective dioceses or corporation sole.
In view of these peculiarities of the corporation sole, it would seem obvious that when
the specific provision of the Constitution invoked by respondent Commissioner
(section 1, Art. XIII), was under consideration, the framers of the same did not have
in mind or overlooked this particular form of corporation. If this were so, as the facts
and circumstances already indicated tend to prove it to be so, then the inescapable
conclusion would be that this requirement of at least 60 per cent of Filipino capital was
never intended to apply to corporations sole, and the existence or not a vested right
becomes unquestionably immaterial.
 AYOG VS CUSI LAUSAN AYOG, ET.AL., VS. JUDGE VICENTE N. CUSI G.R.
NO. L-46729 NOVEMBER 19, 1982
FACTS
On January 21, 1953, the Director of Lands, after bidding, awarded to Biñan
Development Co., Inc. a parcel of land with an area of about two hundred fifty
hectares. The occupants of said land, herein petitioners, were ordered to vacate the
same. Upon the refusal of the occupants of the said, the corporation filed an ejectment
suit. After an investigation, the Director of Lands found out that the occupants entered
the land only after it was awarded to the corporation. Thus, they could not be regarded
as bona fide occupants. On July 18, 1961, the corporation fully paid the purchase
price for the land. More than thirteen years later, the Sales Patent was issued to the
corporation with a reduced area of 175.3 hectares. The petitioners contested that the
adoption of the Constitution which took effect on January 17, 1973, was a supervening
fact which render it legally impossible to execute the trial court’s judgment of awarding
the land in question to the corporation. They invoked the constitutional prohibition,
already mentioned, that "no private corporation or association may hold alienable
lands of the public domain except by lease not to exceed one thousand hectares in
area." The Director of Lands pointed out that the corporation had complied with the
said requirements long before the effectivity of the Constitution and that the applicant
had acquired a vested right to its issuance.

ISSUE
Whether the 1973 Constitution is an obstacle to the implementation of the trial court’s
1964 judgment ejecting the petitioners.

RULING: NO; The Constitutional prohibition has no retroactive application to the sales
application of Binan Development Co., Inc. because it had already acquired a vested
right to the land applied at the time the 1973 Constitution took effect. Moreover, the
corporation’s compliance with the requirements of the Public Land Law for the
issuance of a patent had the effect of segregating the said land from the public
domain.
 GOMEZ VS. CA, 77770, DEC. 15, 1988
FACTS
Petitioners herein applied for the registration of several parcels of land. The court
rendered its decision adjudicating the lots in favor of the petitioners herein and after
the finality of the decision has directed the chief of the general land registration office
to issue the corresponding decrees of registration. The chief submitted a report to the
court a quo stating that some of the lots were already covered by homestead patents
and issued a recommendation to set aside the order. Petitioners contested such
action and now the present case.

Issue:
WON the action of the chief of the LRA was valid.

Ruling:
Examining section 40, we find that the decrees of registration must be stated in
convenient form for transcription upon the certificate of title and must contain an
accurate technical description of the land. This requires technical men. Moreover, it
frequently occurs that only portions of a parcel of land included in an application are
ordered registered and that the limits of such portions can only be roughly indicated
in the decision of the court. In such cases amendments of the plans and sometimes
additional surveys become necessary before the final decree can be entered. That
can hardly be done by the court itself; the law very wisely charges the Chief Surveyor
of the General Land Registration Office with such duties (Administrative Code, section
177).
Thus, the duty of respondent land registration officials to render reports is not limited
to the period before the court’s decision becomes final, but may extend even after its
finality but not beyond the lapse of one (1) year from the entry of the decree.