Mateo Cario vs The Insular Government (December 1906)

January 29, 2012

7 Phil 132 Civil Law Land Titles and Deeds Ancestral Domain Ancestral Land Claim
Political Law Regalian Doctrine
On June 23, 1903, Mateo Cario went to the Court of Land Registration (CLR) to petition his inscription as
the owner of a 146 hectare land hes been possessing in the then municipality of Baguio. Mateo only
presented possessory information and no other documentation. The State opposed the petition averring
that the land is part of the US military reservation. The CLR ruled in favor of Mateo. The State appealed.
Mateo lost. Mateo averred that a grant should be given to him by reason of immemorial use and occupation
as in the previous cases Cansino vs Valdez and Tiglao vs Government; and that the right of the State over
said land has prescribed.
ISSUE: Whether or not Mateo is the rightful owner of the land by virtue of his possession of it for some
time.
HELD: No. The statute of limitations did not run against the government. The government is still the
absolute owner of the land (regalian doctrine). Further, Mateos possession of the land has not been of
such a character as to require the presumption of a grant. No one has lived upon it for many years. It was
never used for anything but pasturage of animals, except insignificant portions thereof, and since the
insurrection against Spain it has apparently not been used by Cario for any purpose.
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 the State remained the absolute
owner.