Separate Concurring Opinion 19 GR. No. 224469 further empowered the Philippine Commission to prescribe the rules for perfecting titles to public lands by qualified applicants. 92 Finally, Section 1693 mandated that in the sale of public domain, actual occupants shall be given preference. 94 Shortly thereafter, or on November 6, 1902, the Land Registration Act was enacted. It established, among others, the Court of Land Registration tasked to hear applications for registration filed pursuant to its provisions. 95 It likewise empowered the Court of Land Registration to adjudicate conflicting claims to title. 96 The enactment of the Land Registration Act saw the implementation of a "complete system of registration on the general lines of the Torrens system." 97 The Torrens system created a guarantee that certificates of title over lands shall be indefeasible98 and that "all claims to the parcel of land are quieted upon issuance of said certificate[,]" 99 thus: 92 93 94 95 96 97 98 99 period have the force and effect•of law in the Philippine Islands: Provided, That a single homestead entry shall not exceed sixteen hectares in extent. Philippine Bill of July 1, 1902, sec. 14 provides: SECTION 14. That the Government of the Philippine Islands is hereby authorized and empowered to enact rules and regulations and to prescribe terms and conditions to enable persons to perfect their title to public lands in said Islands, who, prior to the transfer of sovereignty from Spain to the United States, had fulfilled all or some of the conditions required by the Spanish laws and royal decrees of the Kingdom of Spain for the acquisition of legal title thereto, yet failed to secure conveyance of title; and the Philippine Commission is authorized to issue patents, without compensation, to any native of said Islands, conveying title to any tract of land not more than sixteen hectares in extent, which were public lands and had been actually occupied by such native or his ancestors prior to and on the thirteenth of August, eighteen hundred and ninety-eight. Philippine Bill of July 1, 1902, sec. 16 provides: SECTION 16. That in granting or selling any part of the public domain under the provisions of the last preceding section, preference in all cases shall be given to actual occupants and settlers; and such public lands of the United States in the actual possession or occupancy of any native of the Philippine Islands shall not be sold by said Government to any other person without the consent thereto of said prior occupant or settler first had and obtained: Provided, That the prior right hereby secured to an occupant of land, who can show no other proof of title than possession, shall not apply to more than sixteen hectares in any one tract. Owen James Jr. Lynch, Native Title, Private Right and Tribal Land Law: An Introductory Survey, 57 PHIL. L. J. 268, 276 (1982). Act No. 496, sec. 2 provides: SECTION 2. A court i,s hereby established to be called the "Court of Land Registration," which shall have the exclusive jurisdiction of all applications for the registration under this Act of title to land or buildings or an interest therein within the Philippine Islands, with power to hear and determine all questions arising upon such applications, and also have jurisdiction over such other questions as may come before it under this Act, subject, however, to the right of appeal, as hereinafter provided. The proceedings upon such applications shall be proceedings in rem against the land and the buildings and improvements thereon, and the decrees shall operate directly on the land and the buildings and improvements thereon, and vest and establish title thereto. Owen James Lynch, Jr., Native Title, Private Right and Tribal Land Law: An Introductory Survey, 57 PHIL. L. J. 268, 281 (1982). Owen James Lynch, Jr., Invisible Peoples and a Hidden Agenda: The Origins of Contemporary Philippine Land Laws, 63 PHIL. L. J. 249, 281 (1988). Id. at 282. J. Puno, Separate Opinion in Cruz v. Secretary of Natural Resources, 400 Phil. 904, 941 (2000) [Per Curiam, En Banc].

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