Stat Con Chap 3 Cases .pdf - STATUTORY CONSTRUCTION CHAPTER 3 AIDS TO CONSTRUCTION Statutory Construction Case 1 SAM City of Baguio vs Hon Pio R Marcos

Stat Con Chap 3 Cases .pdf - STATUTORY CONSTRUCTION CHAPTER...

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STATUTORY CONSTRUCTION CHAPTER 3: AIDS TO CONSTRUCTION Statutory Construction Case 1 - SAM City of Baguio vs. Hon. Pio R. Marcos February 28, 1969 | Sanchez, J. | Title of a Statute – an aid to construction PETITIONERS : City of Baguio, Reforestation Administration, Francisco G. Joaquin Sr., Francisco G. Joaquin Jr., and Teresita J. Buchholz RESPONDENTS : Hon. Pio R. Marcos, Belong Lutes, Court of Appeals SUMMARY : On April 12, 1912, the Director of Lands in the Court of First Instance of Baguio instituted the reopening of cadastral proceedings, Civil Registration Case No.1. The land involved in the case is Baguio Townsite, which was declared as public land by final decision dated November 13, 1922. 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. The contention of the respondents that is relevant and relative to our discussion is the first one which is the reopening petition was filed outside the 40-year period provided by R.A. 931. The title of R.A 931 reads, “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” The basis of the contention of the respondents comes from a phrase of Section 1 of R.A. 931, which reads “…by virtue of judicial proceedings instituted within the forty years next preceding the approval of this Act”. There is an apparent inconsistency between the Title and the Body of the statute The issue is whether or not the filing of the petition fell within the 40-year period provided by R.A. 931 which was enacted on June 20, 1953. When would the 40-year prescription reckon, will it be the date of the proceeding – April 12, 1912 or the date of the decision – November 13, 1922? If the reckoning period would be the date of the PROCEEDING, Marcos’ petition would NOT have been valid (41 years) . On the other hand, if the date of reckoning would be the date of DECISION, the petition would be VALID. (31 years) The court held in reopening the civil case since it found that the petition was filed within the 40-year period provided by the Act basing its decision with the title of R.A 931 and not Section 1. DOCTRINE: The Title of a statute serves as aid, in case of doubt in its language, to its construction and to ascertaining legislative will.
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