Case #/ Name G.R. No. L-26100.

February 28, 1969

Parties City of Baguio vs. Marcos

Topic/Point of Discussion Title

Facts
In April 12, 1912, the director of lands in the CFI of Baguio INSTITUTED the reopening of cadastral
proceedings. In November 13, 1922, a decision was RENDERED. The land involved was the Baguio
Townsite which was declared public land. In July 25, 1961, Belong Lutes petitioned to reopen the
civil case on the following grounds: 1) he and his predecessors have been in continuous possession
and cultivation of the land since Spanish times; 2) his predecessors were illiterate Igorots, thus,
were not able to file their claim. On the contrary, F. Joaquin Sr., F. Joaquin Jr., and Teresita Buchholz
opposed Lutes’ reopening on the following grounds: 1) the reopening was filed outside the 40-year
period provided in RA 931; 2) the petition to reopen the case was not published; and 3) as lessees of
the land, they have standing on the issue.

Issue Whether or not the reopening of the peririon was filed outside the 40-year period provided in RA
931, which was ENACTED on June 20, 1953
Held/Ruling
The Supreme Court granted the reopening of cadastral proceedings

The title of RA 931 was “An Act to Authorize the Filing in Proper Court under Certain Conditions, of
Certain Claims of Title to Parcels of Land that have been Declared Public Land, by Virtue of Judicial
Decisions RENDERED within the 40 Years Next Preceding the Approval of this Act.” Section 1 of the
Act reads as “..in case such parcels of land, on account of their failure to file such claims, have been,
or about to be declared land of the public domain by virtue of judicial proceedings INSTITUTED
within the 40 years next preceding the approval of this act.” If the title is to be followed, November
13, 1922 is the date which should be followed, hence, would allow the reopening of the case. If
Section 1 is to be followed, the date of the institution of reopening of the case which was April 12,
1912, the petition would be invalid.

StatCon maxim: The title is an indispensable part of a statute, and what may inadequately be
Supplemental Notes omitted in the text may be supplied or remedied by its title.