Facts: In July 1, 1919, Ana Ramirez contracted with the Central Capiz to supply to it for a term of 30 years all sugar cane produced upon her plantation. Knowing her obligation, Ramirez refused to do so upon the fact that more than 61% of the capital stock of the petitioner is held and owned by persons who are not citizens of the Philippines or of United States. The land involved is a private agricultural land.
Issue: Whether or not Act No. 2874, also known as Public Land Act is applicable t agricultural lads which are privately owned
Held: Public Land Act is inapplicable to the lands of the respondents
Ratio: The title of the act was “An Act to Amend and Compile the Laws Relating to Lands of the Public Domain and Other Purposes.” Section 1 of the act provides that the short title of the act shall be “The Public Land Act.” Section2 provides that “the provisions of this act shall apply to lands of the public domain.” The “and for other purposes” in the title is non-existent. Agricultural lands in private ownership constitute no part of the public domain.
StatCon maxim: The title may indicate the legislative intent to extend or restrict the scope of the law and a statute couched in a language of doubtful import will be construed to conform to the legislative intent as disclosed in its title.
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