04/02/2020
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"x x x to the end that any and all persons who, since the year 1700, and
up to the date of the promulgation and publication of said order, shall
have occupied royal lands, whether or not x x x cultivated or tenanted,
may x x x appear and exhibit to said subdelegates the titles and patents
by virtue of which said lands are occupied. x x x. Said subdelegates will
at the same time warn the parties interested that in case of their failure
to present their title deeds within the term designated, without a just and
valid reason therefor, they will be deprived of and evicted from their
lands, and they will be granted to others."[15]
On June 25, 1880, the Crown adopted regulations for the adjustment of lands
"wrongfully occupied" by private individuals in the Philippine Islands. Valenton
construed these regulations together with contemporaneous legislative and
executive interpretations of the law, and concluded that plaintiffs' case fared no
better under the 1880 decree and other laws which followed it, than it did under the
earlier ones. Thus as a general doctrine, the Court stated:
"While the State has always recognized the right of the occupant to a
deed if he proves a possession for a sufficient length of time, yet it has
always insisted that he must make that proof before the proper
administrative officers, and obtain from them his deed, and until
he did that the State remained the absolute owner."[16]
In conclusion, the Court ruled: "We hold that from 1860 to 1892 there was no law
in force in these Islands by which the plaintiffs could obtain the ownership of these
lands by prescription, without any action by the State."[17] Valenton had no rights
other than those which accrued to mere possession. Murciano, on the other hand,
was deemed to be the owner of the land by virtue of the grant by the provincial
secretary. In effect, Valenton upheld the Spanish concept of state ownership of
public land.
As a fitting observation, the Court added that "[t]he policy pursued by the
Spanish Government from earliest times, requiring settlers on the public
lands to obtain title deeds therefor from the State, has been continued by
the American Government in Act No. 926."[18]
C. The Public Land Acts and the Torrens System
Act No. 926, the first Public Land Act, was passed in pursuance of the provisions of
the the Philippine Bill of 1902. The law governed the disposition of lands of the
public domain. It prescribed rules and regulations for the homesteading, selling, and
leasing of portions of the public domain of the Philippine Islands, and prescribed the
terms and conditions to enable persons to perfect their titles to public lands in the
Islands. It also provided for the "issuance of patents to certain native settlers upon
public lands," for the establishment of town sites and sale of lots therein, for the
completion of imperfect titles, and for the cancellation or confirmation of Spanish
concessions and grants in the Islands." In short, the Public Land Act operated on the
assumption that title to public lands in the Philippine Islands remained in the
government;[19] and that the government's title to public land sprung from the
elibrary.judiciary.gov.ph/thebookshelf/showdocsfriendly/1/36882
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