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STATUTORY CONSTRUCTION CHAPTER 3: AIDS TO CONSTRUCTIONStatutory 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 FirstInstanceofBaguioinstituted the reopening of cadastral proceedings, CivilRegistration Case No.1. The land involved in the case is Baguio Townsite, whichwas 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 thegrounds that 1.) he and his predecessors have been in continuous possession andcultivation of the land since Spanish times 2.) his predecessors were illiterateIgorots, 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 TeresitaJ. 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 isthe first one which is the reopening petition was filed outside the 40-year periodprovided by R.A. 931. The title of R.A 931 reads, “AN ACT TO AUTHORIZE THE FILING IN THEPROPER COURT, UNDER CERTAIN CONDITIONS, OF CERTAIN CLAIMSOFTITLETOPARCELSOF LAND THAT HAVE BEEN DECLAREDPUBLICLAND,BY VIRTUE OFJUDICIAL DECISIONSRENDEREDWITHIN THE FORTY YEARS NEXT PRECEDING THE APPROVAL OFTHIS ACT” The basis of the contention of the respondents comes from a phrase of Section 1 ofR.A. 931, which reads “…by virtue ofjudicial proceedingsinstituted within theforty years next preceding the approval of this Act”. There is an apparent inconsistency between the Titleand the Bodyof the statute The issue is whether or not the filing of the petition fell within the 40-year periodprovided by R.A. 931 which was enacted on June 20, 1953. When would the40-year prescription reckon, will it be the date of theproceeding– April 12, 1912or the date of the decision– November 13, 1922? If the reckoning period would be the date of the PROCEEDING, Marcos’ petitionwould NOT have been valid(41 years). On the other hand, if the date ofreckoning would be the date of DECISION, the petition would be VALID.(31years) The court held in reopening the civil case since it found that the petition was filedwithin the 40-year period provided by the Act basing its decision with the title ofR.A 931 and not Section 1. DOCTRINE: The Title of a statute serves as aid, in case of doubt in its language, to itsconstruction and to ascertaining legislative will.