City of Baguio v. Marcos G.R. No. L-26100. February 28, 1969

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: The Supreme Court grabted the reopening of cadastral proceedings

Ratio: 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 omitted in the text may be supplied or remedied by its title.