TITLE: CITY OF BAGUIO, REFORESTATION ADMINISTRATION, FRANCISCO G.

JOAQUIN, SR., FRANCISCO G. JOAQUIN, JR., and TERESITA J. BUCHHOLZ,

petitioners, vs. HON. PIO R. MARCOS, Judge of the Court of First Instance of Baguio,
BELONG LUTES, and THE HONORABLE COURT OF APPEALS, respondents.
G.R. No. L-26100 28 February 1969
PONENTE: NATURE:
FACTS:
On April 12, 1912, the Director of Lands in the Court of First Instance of Baguio
instituted the reopening of cadastral proceedings (a land registration/ titling proceeding) Civil
Case No.1. A decision on November 13, 1922 was rendered; the land involved (Baguio
Townsite) was among those declared public lands.

On July 25, 1961, Belong Lutes petitioned cadastral court to reopen said civil case. He
claims that the land (Baguio Townsite) be registered in his name upon the grounds that 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
to the land in question.

On the other hand, Francisco G. Joaquin Sr., Francisco G. Joaquin, Jr. and Teresita J.
Buchholz, as tree farm lessees of the land in question, opposed the reopening. Their contentions
are as follows: 1.) The reopening petition was filed outside the 40-year period provided by R.A.
931 2.) Petition to reopen the case was not published 3.) As lessees of the land, they have a
standing to appear in the reopening proceedings
ISSUE/S:
Whether or not the reopening petition was filed outside the 40-year period provided by
R.A. 931 (enacted June 20, 1953)
DOCTRINES | HELD:
The office of statutory interpretation is to determine legislative intent. When engaged in
the task of construing an obscure expression in the law or where exact or literal rendering of the
words would not carry out the legislative intent, the title thereof may be resorted to in the
ascertainment of congressional will. Reason therefor is that the title of the law may properly be
regarded as an index of or clue or guide to legislative intention. This is especially true in this
jurisdiction. It has been observed that "in modern practice the title is adopted by the Legislature,
more thoroughly read than the act itself, and in many states is the subject of constitutional
regulation." The constitutional injunction that the subject of the statute must be expressed in the
title of the bill, breathes the spirit of command because "the Constitution does not exact of
Congress the obligation to ready during its deliberations the entire text of the bill." Reliance,
therefore, may be placed on the title of a bill, which, while not an enacting part, no doubt "is in
some sort a part of the act, although only a formal part." These considerations are all the more
valid here because R.A. 931 was passed without benefit of the congressional debate in the House
from which it originated as House Bill 1410, and in the Senate.

RULING:
NO. The court allowed the reopening of the case since the case was filed within the 40-
year period imposed by the act.
 Joaquin’s group believes that the difference between the title (BY VIRTUE OF
JUDICIAL DECISIONS RENDERED and in section 1 (by virtue of judicial proceedings
instituted), is material. If the title is to be followed, the date November 13, 1922 should be the
date used in reckoning the period (which is still within the 40-year period; counted from the date
of the enactment of R.A. 931 which is June 20, 1953). But if the wordings of the title are to be
followed, the date April 12, 1912, which is the date the Director of lands instituted the reopening
of the case, would render the petition invalid since it is already outside the 40-year period.

The rule on statutory construction provides that laws should be construed liberally The
spirit or the intent of the law should be looked upon and should prevail over its letter. In this
case, R.A. 931 clearly gives an opportunity to any person who has any interest in any parcel of
land which has been declared as public land to present his claim within the time prescribed. This
act is a piece of remedial legislation; its intent provides a mode of relief to landowners who,
before the act had no legal means of perfecting titles. Therefore, the court cannot see an
inconsistency between the title and its section.

The title of the act is indisputably clear, as it expresses the very substance of the law
itself. The constitutional jurisdiction that the subject of the statute must be expressed in the title,
breathes the spirit of command because the constitution does not exact of Congress the
obligation to read during its deliberations the entire text of the bill. Therefore, by the statute, the
petition of Lutes to reopen the case, decision on which was rendered on Nov. 13, 1922, comes
within the 40-year period.
NOTES:
Republic Act 931, effective June 20, 1953. "AN ACT TO AUTHORIZE THE
FILING IN THE 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 FORTY
YEARS NEXT PRECEDING THE APPROVAL OF THIS ACT."

Section 1 thereof provides —

“…in case such parcels of land, on account of their failure to file such claims, have been,
or are about to be declared land of the public domain by virtue of judicial proceedings instituted
within the forty years next preceding the approval of this Act, are hereby granted…”