Separate Concurring Opinion 16 G.R. No. 224469 legal disenfranchisement. 72 On June 25, 1880, a Royal Decree was enacted stating that "all persons in possession of real property were to be considered owners provided they, had in good faith occupied and possessed their claimed land for at least [10] years." 73 The Royal Decree of 1880 was followed by the Spanish Mortgage Law which had for its purpose "the systematic registration of land titles and deeds as well as for possessory claims." It was adopted as a means of registering and subjecting to taxation the ~and_s held pursuant to the Royal Decree of 1880. The law provided that '"owners who lack recorded title of ownership' could have their interests registered during a possessory information proceeding[.]" However, the title was a mere record of possession which can later be converted into a record of ownership after 20 years from its date of issue. 74 By 1894, the unresolved applications for official documentary recognition of ownership reached 200,000. The natives were unable to show titles to their lands except by actual possession. The natives were presumed to be unaware of the Spanish laws concerning registration and documentation of lands by reason of "[t]he uneven Spanish impact, abuses by colonial officials, the absence of effective notice, illiteracy, lack of money to pay for transportation fares and legal prerequisites, e.g. filing fees, attorney's fees, survey costs[.]" 75 In a final attempt to remedy the. problems concerning property registration, the Spanish Government issued the Royal Decree of February 13, 1894, otherwise known as the Maura Law. It was the last land law promulgated by the Spanish colonial regime in the Philippines. 76 The preamble provided that the law's purpose is to, "insure to the natives, in the future, whenever it may be possible, the necessary land for cultivation, in accordance with traditional usages." 77 However, a contrary intention was revealed in Article 4 of the law, which provides: The title to all agricultural lands which were capable of adjustment under the Royal Decree of 1880, but the adjustment of which has not been sought at the time of promulgation of this Decree ... will revert to the State. 72 73 74 75 76 77 John Jerico Laudet Balisnomo, Ancestral Domain Ownership and Disposition: Whose Land, Which Lands, 42 ATENE0 L. J. 159, 174 (1997). Owen James Lynch, Jr., Native Title, Private Right and Tribal Land Law: An Introductory Survey, 57 PHIL. L. J. 268, 275 (1982). See also John Jerico Laudet Balisnomo, Ancestral Domain Ownership and Disposition: Whose Land, Which Lands, 42 ATENE0 L. J. I 59, 174 (1997). Id. Owen James Lynch, Jr., Land Rights, Land Laws and Land Usurpation: The Spanish Sea (I 565-1898), 63 PHIL. L. J. 82, 107 (1988). Id. at I 08. Owen James Lynch, Jr., Native Title, Private Right and Tribal Land Law: An Introductory Survey, 57 PHIL. L. J. 268, 275 (1982). I