City of Baguio, Reforestation Administration, and Francisco G. Joaquin, Sr., Francisco G. Joaquin, Jr.

,
and Teresita J. Buchholz VS. Hon. Pio R. Marcos and Belong Lutes
G.R. No. L-26100, February 28, 1969
SANCHEZ, J.:

FACTS: On 12 April 1912, the Director of Lands in Court of First Instance of Baguio instituted to
reopen the cadastral proceedings over a parcel of land located in Baguio Townsite under RA 931. On
13 November 1922, a final decision was rendered in which the land involved was among the
declared as public lands.

On 25 July 1961, Belong Lutes petitioned to reopen the civil case on the following grounds: 1) he and
his predecessors have been in actual and continuous possession and cultivation of the land since
Spanish time and paying the taxes; and 2) his predecessors were illegitimate Igorots without
personal notice of the cadastral proceedings and were not able to claim the land in question within
the statutory period. However, on 18 December 1961, private petitioners Francisco Joaquin Sr,
Francisco Joaquin, Jr., and Teresita Buchholz opposed Lutes’ petition of reopening. They also
questioned the cadastral court’s jurisdiction over the petition to reopen.

ISSUE: Was the reopening petition filed outside the 40 year period preceding the approval of RA
931?

HELD: No. The Court ruled that the petition to reopen filed by Lutes was within the 40-year period
under the RA 931. It shall be noted that cadastral proceedings sought to be reopened were
instituted on 12 April 1912 and a final decision was rendered on 13 November 1922. Lutes filed the
petition to reopen on 25 July 1961, 39 years after a judicial decision on the land in question was
rendered.

In the case at bar, the title of RA 31 authorizes the filing in proper court, under certain conditions, of
certain claims of title to parcels of land that have been declared public by virtue of judicial decisions
rendered within 40 years preceding the approval of this Act. However, the body of RA 931 speaks of
parcels of land that have been or are about to be declared of public domain by virtue of judicial
proceedings instituted within 40 years preceding the approval of this act.

As a rule in statutory construction, the true object of all interpretation is to ascertain the meaning
and will of the law-making body. In construing an obscure expression in the law or the exact or literal
rendering of the words would not carry out the legislative intent, the title of such laws may be
resorted to ascertain the congressional will. The title of the law may properly be regarded as an
index of or clue or guide to legislative intention. The title of this Act recites that it authorizes court
proceedings of claims of parcels of land declared public land "by virtue of judicial decisions rendered
within the forty years next preceding the approval of this Act. This has no contradiction to the
provisions expressed in the body. The words "by virtue of judicial decisions rendered" in the title of
the law stand in equal importance to the phrase in Section 1 thereof, "by virtue of judicial
proceedings instituted." Further, there should be no quibbling as to the fact that R.A. 931 is a piece
of remedial legislation. In essence, it provides a mode of relief to landowners who, before the Act,
had no legal means of perfecting their titles.

Hence, the petition to reopen the civil case over the parcel of land located in Baguio Townsite filed
by Lutes on 25 July 1961 was within the 40-year period as prescribed under RA 931.