Republic of the Philippines vs. National Commission on Indigenous Peoples

Section 78 of RA 8371 excludes the City of Baguio and lands proclaimed as part of its townsite reservation from the coverage of the IPRA; the NCIP has no authority to issue CALTs or CADTs over such lands, and reclassification is solely for Congress through appropriate legislation. The exception for prior land rights and titles recognized or acquired before the effectivity of the IPRA did not apply because the respondents' rights were never recognized in any administrative or judicial proceeding prior to the IPRA.

The Republic, through the Office of the Solicitor General, challenged resolutions of the National Commission on Indigenous Peoples that issued Certificates of Ancestral Land Title to the heirs of Cosen Piraso and Josephine Molintas Abanag and other private respondents. The dispute turns on Section 78 of RA 8371, the Indigenous Peoples' Rights Act of 1997, which Congress enacted against the backdrop of Baguio City's charter and the Baguio Townsite Reservation established in 1912. Baguio City was incorporated on 1 September 1909, and the Baguio Townsite Reservation was established on 12 April 1912; the reservation's public and private portions were later the subject of registration proceedings.

Baguio City was incorporated on 1 September 1909, and on 12 April 1912 the Baguio Townsite Reservation was established. Upon the establishment of the reservation, there remained a question as to what portions of the reservation were public and private. If declared private, such lands were registrable under Act No. 496, or the Land Registration Act, as provided for by Act No. 926, or the Public Land Act. In 1912, Civil Reservation Case No. 1, General Land Registration Office Reservation Record No. 211, was filed with the Court of Land Registration to resolve which lands were declared public and private. Pursuant to Section 62 of Act No. 926, the Court of First Instance of Benguet issued a notice on 22 July 1915 requiring all persons claiming lots inside the Baguio Townsite Reservation to file within six months from the date of the notice petitions for the registration of their titles under Act No. 496. On 14 June 1922, the General Land Registration Office submitted to the Court of First Instance a report on the applications for registration, and the case was duly heard. On 13 November 1922, the Court of First Instance of Benguet, in resolving Civil Reservation Case No. 1, held that all claims for private lands by all persons not presented for registration within the period in Act No. 627 are barred forever. Notwithstanding the Court of First Instance decision, several native residents of Baguio City sought the exclusion of lands occupied by them from the Baguio Townsite Reservation. Thus, on 16 August 1954, President Ramon Magsaysay issued Administrative Order No. 55, series of 1954, authorizing the formation of a committee to study the claims of the inhabitants, with a view of determining whether it was in the public interest that the said landholdings be segregated from the Baguio Townsite Reservation and opened to disposition under the Public Land Act. Forty-eight Igorot claimants originally filed claims under the said administrative order, and two hundred eighty-five others later filed additional claims. Respondents were not among the original and additional claimants.

The heirs of Cosen "Sarah" Piraso, the daughter of Piraso, otherwise known as Kapitan Piraso, an Ibaloi, occupied an ancestral land located at what is known as Session Road, Baguio City. Aside from having five children, Kapitan Piraso also adopted, in accordance with the Ibaloi tradition, a son in the name of Nimer. Nimer and his family, in turn, had been planting and harvesting vegetables and fruit-bearing trees on several portions of the ancestral land. Thereafter, the petitioners, as represented by Richard A. Acop, filed an application for the identification, delineation and recognition of the ancestral land initially before the Baguio NCIP City Office pursuant to the provisions of RA 8371. The petitioners alleged that the subject ancestral land had been occupied, possessed, and utilized by them and their predecessors-in-interest for so many years. Subsequently, the NCIP recognized the petitioners' rights over the subject parcels of ancestral land after finding that the genealogy of the petitioners shows an unbroken line of generations starting from Piraso who have never left the subject ancestral land for the last 120 years. In view of said findings, the NCIP ordered the issuance of eight Certificates of Ancestral Land Titles under the petitioners' names as well as that of Nimer.

With respect to the Abanag claim, the petitioners are the heirs of Josephine Molintas Abanag, who in turn was a descendant of an Ibaloi native named Menchi. Menchi originally owned several parcels of ancestral land located in various parts of what is now known as Baguio City, and these parcels were subsequently inherited by his descendants. Consequently, the petitioners, as represented by Isaias M. Abanag and Marion T. Pool, filed a petition for the identification, delineation and recognition of their ancestral lands in Baguio City pursuant to RA 8371. Thereafter, an ocular inspection was conducted which revealed the coverage of the ancestral lands of the Molintas. In addition, the petitioners therein also submitted numerous pieces of documentary evidence such as the narrative of customs and traditions of the Ibaloi community in Baguio City, Assessment of Real Property, Tax receipts, photographs of improvements, rituals, and members of the Molintas family led by Josephine Molintas Abanag. In the end, the NCIP granted the petition and ordered the issuance of twenty-eight CALTs covering the same number of parcels of ancestral land in the name of the petitioners and Joan L. Gorio, a transferee of ten parcels of land from the heirs of Josephine Molintas Abanag. There was a Deed of Undertaking by the petitioners supporting their claim.

In its Resolution Nos. 107-2010-AL and 108-2010-AL dated 10 November 2010, the NCIP held that the private respondents Pirasos and Abanags have vested rights over their ancestral lands on the basis of a native title and as mandated by Article XII, Section 5 of the 1987 Constitution and RA 8371. The NCIP described native title as the interests and rights of indigenous inhabitants in land, whether communal, group or individual, possessed under the traditional laws acknowledged by, and the traditional customs observed by, the indigenous inhabitants. It held that native title has its origin in and is given its content by the traditional laws acknowledged by and the traditional customs observed by the indigenous inhabitants of a territory, and that the nature and incidents of native title must be ascertained as a matter of fact by reference to those laws and customs. The NCIP ruled in both Resolutions that the Pirasos and the Abanags are guaranteed the right to their ancestral lands provided for under Section 8 of RA 8371 and such other rights granted by law. The Land Registration Authority subsequently issued the corresponding Transfer Certificates of Title covering the said properties. The subject CALTs cover almost one-fifth of the 57.49 square kilometers that comprise Baguio City. Almost two years after, the Republic of the Philippines, as represented by the Office of the Solicitor General, sought to annul, reverse and set aside the assailed Resolutions of the NCIP. The Republic also sought the issuance of a writ of preliminary prohibitory injunction and a permanent injunction to restrain and enjoin the NCIP from further issuing Certificates of Ancestral Domain Title and CALTs in Baguio City.

The subject lots in the present case were not shown to be part of any ancestral land prior to the effectivity of the IPRA. Private respondents' rights over the subject properties located in the Townsite Reservation in Baguio City were never recognized in any administrative or judicial proceedings prior to the effectivity of the IPRA law. Under Republic vs. Fañgonil, 134 persons living upon or in visible possession were personally served with the notice of reservation, and Section 3 of Act No. 627 provides that the certification by the clerk of court is conclusive proof of service of the said notice. Since respondents in the present case claim possession since time immemorial, their predecessors were necessarily given notice of the reservation and, hence, should have filed their claims within the stated period. No such claim was filed.

• Coverage of IPRA in Baguio City: Petitioner argued that the Court of Appeals committed a reversible error when it declared that lands within Baguio City and the Baguio Townsite Reservation are covered by the IPRA, contrary to law and jurisprudence.
• Section 78 Exemption: Petitioner maintained that the Baguio Townsite Reservation, with the exception of existing property rights recognized or vested before the effectivity of the IPRA, is exempt from the coverage of the IPRA as provided in Section 78 thereof.
• NCIP Jurisdiction: Petitioner argued that the NCIP has no jurisdiction to issue CALTs over lands within Baguio City and the Baguio Townsite Reservation, outside of those over which prior land rights and titles have been earlier recognized by judicial, administrative, or other processes before the effectivity of the IPRA.
• Validity of NCIP Resolutions: Petitioner contended that the Court of Appeals committed a reversible error when it ruled that the assailed NCIP Resolutions are valid, contrary to the Constitution and applicable laws and jurisprudence.
• Conversion to TCTs: Petitioner argued that, assuming arguendo that the subject CALTs are valid, the Court of Appeals committed reversible error when it upheld the issuance of TCTs based on the CALTs, because there is no law which allows their conversion into Torrens certificates of title.
• Injunctive Relief: Petitioner sought the issuance of a writ of preliminary prohibitory injunction and a permanent injunction to restrain and enjoin the NCIP from further issuing CADTs and CALTs in Baguio City.

• Coverage of IPRA in Baguio City: Whether lands within Baguio City and the Baguio Townsite Reservation are covered by the Indigenous Peoples' Rights Act of 1997.
• NCIP Jurisdiction: Whether the NCIP has jurisdiction to issue CALTs over lands within Baguio City and the Baguio Townsite Reservation, outside of those over which prior land rights and titles were recognized before the effectivity of the IPRA.
• Validity of NCIP Resolutions and CALTs: Whether NCIP Resolution Nos. 107-2010-AL and 108-2010-AL and the CALTs issued pursuant thereto are valid.
• Conversion to TCTs: Whether the corresponding TCTs and derivative titles issued based on the CALTs are valid.

• Coverage of IPRA in Baguio City: No. Section 78 of RA 8371 expressly excludes the City of Baguio and lands proclaimed as part of its townsite reservation from the general provisions of the IPRA; Baguio City remains governed by its own charter.
• NCIP Jurisdiction: No. The NCIP has no legal authority to issue CALTs or CADTs over properties included as Townsite Reservation areas in Baguio City; the power to reclassify such lands is solely vested in Congress through appropriate legislation.
• Validity of NCIP Resolutions and CALTs: Void. The NCIP resolutions and CALTs covering lands within the Baguio Townsite Reservation are void because the NCIP acted without authority and because the respondents' rights were never recognized in any administrative or judicial proceeding prior to the effectivity of the IPRA.
• Conversion to TCTs: Void. The corresponding TCTs and all derivative titles issued based on the void CALTs were declared null and void.

• Coverage of IPRA in Baguio City: Section 78 of RA 8371 provides that the City of Baguio shall remain to be governed by its Charter and all lands proclaimed as part of its townsite reservation shall remain as such until otherwise reclassified by appropriate legislation, with the proviso that prior land rights and titles recognized and/or acquired through any judicial, administrative or other processes before the effectivity of the Act shall remain valid, and that the provision shall not apply to any territory which becomes part of the City of Baguio after the effectivity of the Act. The Court construed Section 78 as mandating that (1) the City of Baguio shall not be subject to the provisions of the IPRA but shall still be governed by its own charter; (2) all lands previously proclaimed as part of the City of Baguio's Townsite Reservation shall remain as such; (3) the reclassification of properties within the Townsite Reservation can only be made through a law passed by Congress; (4) prior land rights and titles recognized and acquired through any judicial, administrative or other process before the effectivity of the IPRA shall remain valid; and (5) territories which became part of the City of Baguio after effectivity of the IPRA are exempted. Thus, for properties part of the townsite reservation of Baguio City before the passage of the IPRA, no new CALT or CADT can be issued by the NCIP. Rule XIII, Section 1 of the IPRA Implementing Rules reiterates that lands within the Baguio Townsite Reservation shall not be reclassified except through appropriate legislation. Congressional deliberations on House Bill No. 9125 and Senate Bill No. 1728, which became RA 8371, reveal the clear intent to exempt Baguio City's land areas, particularly the Baguio City Townsite Reservation, from the coverage of the IPRA. The NCIP cannot transgress this clear legislative intent. Absent legislation passed by Congress, the Baguio Townsite Reservation shall belong to the public and exclusively for public purpose. The Wright Park, the Secretary's Cottage, the Senate President's Cottage, the Mansion House, and the public roads therein, which are all covered by the assailed CALTs, shall remain to exist for the benefit and enjoyment of the public. These subject lands comprise historical heritage and belong to the State under Article 420 of the Civil Code, which classifies as property of public dominion those intended for public use and those which belong to the State, without being for public use, and are intended for some public service or for the development of the national wealth.

• NCIP Jurisdiction: Under RA 8371, the NCIP is devoid of any power to reclassify lands previously included as part of the Townsite Reservation of Baguio City before RA 8371 was enacted. The power to reclassify these properties is solely vested in Congress and can only be exercised through the enactment of a new law. Section 78 of the IPRA is clear that the Charter of Baguio City shall govern the determination of land rights within Baguio City and not the IPRA. The declaration by Congress is conclusive. While the IPRA does not generally authorize the NCIP to issue ancestral land titles within Baguio City, Section 78 recognizes exceptions: (1) prior land rights and titles recognized and acquired through any judicial, administrative or other process before the effectivity of the IPRA; and (2) territories which became part of Baguio after the effectivity of the IPRA. For prior land rights, the remedy afforded to indigenous cultural communities is Act No. 926, particularly Section 32 on free patents to native settlers. On 1 September 1909, Baguio City was incorporated, and on 12 April 1912, the Baguio Townsite Reservation was established. Upon the establishment of the reservation, there remained a question as to what portions were public and private. If declared private, such lands were registrable under Act No. 496 as provided for by Act No. 926. In 1912, Civil Reservation Case No. 1, GLRO Reservation Record No. 211, was filed with the Court of Land Registration. Under Act No. 627, any landowner affected by the declaration of military reservations must register their titles within the period stated in the Land Registration Act; otherwise, such land rights would be considered barred. Pursuant to Section 62 of Act No. 926, the Court of First Instance of Benguet issued a notice on 22 July 1915 requiring all persons claiming lots inside the Baguio Townsite Reservation to file within six months from the date of the notice petitions for the registration of their titles under Act No. 496. On 14 June 1922, the General Land Registration Office submitted to the Court of First Instance a report on the applications for registration, and the case was duly heard. On 13 November 1922, the Court of First Instance of Benguet, in resolving Civil Reservation Case No. 1, held that all claims for private lands by all persons not presented for registration within the period in Act No. 627 are barred forever. Notwithstanding the Court of First Instance decision, several native residents of Baguio City sought the exclusion of lands occupied by them from the Baguio Townsite Reservation. Thus, on 16 August 1954, President Ramon Magsaysay issued Administrative Order No. 55, series of 1954, authorizing the formation of a committee to study the claims of the inhabitants, with a view of determining whether it was in the public interest that the said landholdings be segregated from the Baguio Townsite Reservation and opened to disposition under the Public Land Act. Forty-eight Igorot claimants originally filed claims, and two hundred eighty-five others later filed additional claims. Respondents were not among the original and additional claimants. In Republic vs. Fañgonil, the Court laid to rest claims within the Baguio Townsite Reservation. There, the alleged claims were not previously claimed by the predecessors-in-interest and, therefore, the Court declared that the said properties were not susceptible of registration. Since the claimants did not base their applications under Act No. 496 or any purchase from the State, the Court held that the said claims were not considered valid native claims. Under Fañgonil, 134 persons living upon or in visible possession were personally served with the notice of reservation, and Section 3 of Act No. 627 provides that the certification by the clerk of court is conclusive proof of service of the said notice. Since respondents in the present case claim possession since time immemorial, their predecessors were necessarily given notice of the reservation and, hence, should have filed their claims within the stated period. However, no such claim was filed. In fact, the said lots in the present case were not shown to be part of any ancestral land prior to the effectivity of the IPRA. Private respondents' rights over the subject properties located in the Townsite Reservation in Baguio City were never recognized in any administrative or judicial proceedings prior to the effectivity of the IPRA law. The CALTs and CADTs issued by the NCIP to respondents are thus void.

• Validity of NCIP Resolutions and CALTs: Because the NCIP lacked legal authority to issue CALTs or CADTs over properties included as Townsite Reservation areas in Baguio City, and because the respondents' claimed rights were never recognized in any administrative or judicial proceeding before the effectivity of the IPRA, the NCIP resolutions and the CALTs issued pursuant thereto are void. The Court declared NCIP Resolution Nos. 107-2010-AL and 108-2010-AL, O-CALT Nos. 129 and 130, including the corresponding TCTs with the listed CALT numbers, and all derivative titles issued subsequent to the filing of the petition null and void.

• Conversion to TCTs: The corresponding TCTs issued by the Land Registration Authority based on the void CALTs, as well as all derivative titles issued subsequent to the filing of the petition, were declared null and void. The dispositive portion expressly included the TCTs corresponding to the CALT numbers and all derivative titles thereto.

• Section 78 IPRA Special Provision / Baguio Townsite Reservation Exemption — Section 78 of RA 8371 is a special provision that excludes the City of Baguio and lands proclaimed as part of its townsite reservation from the coverage of the IPRA. It mandates that Baguio City shall remain governed by its charter, that townsite reservation lands shall remain as such until otherwise reclassified by appropriate legislation, that reclassification can only be made by Congress, that prior land rights and titles recognized or acquired before the IPRA remain valid, and that territories becoming part of Baguio after the IPRA are exempted. The Court applied this provision to hold that the NCIP cannot issue new CALTs or CADTs over lands within the Baguio Townsite Reservation.

• Reclassification Power Vested in Congress — The power to reclassify lands previously included as part of the Baguio Townsite Reservation is solely vested in Congress and can only be exercised through the enactment of a new law. The NCIP is devoid of any power to reclassify such lands. The Court relied on this doctrine to invalidate the NCIP resolutions and CALTs.

• Prior Land Rights and Titles Exception — Under Section 78 of RA 8371, prior land rights and titles recognized and/or acquired through any judicial, administrative or other processes before the effectivity of the IPRA remain valid. The Court held that this exception did not apply to the respondents because their rights over the subject properties were never recognized in any administrative or judicial proceeding prior to the effectivity of the IPRA.

• Bar by Prior Registration Proceedings under Act No. 627 and Civil Reservation Case No. 1 — Under Act No. 627, any landowner affected by the declaration of military reservations must register their titles within the period stated in the Land Registration Act; otherwise, such land rights are barred. In Civil Reservation Case No. 1, the Court of First Instance of Benguet held on 13 November 1922 that all claims for private lands not presented for registration within the period in Act No. 627 are barred forever. The Court applied this doctrine, through Republic vs. Fañgonil, to hold that the respondents' claims, based on possession since time immemorial, were necessarily covered by the notice and should have been filed within the stated period; no such claim was filed.

• Public Dominion under Article 420, Civil Code — Article 420 of the Civil Code classifies as property of public dominion those intended for public use, such as roads, canals, rivers, ports, and bridges, and those which belong to the State, without being for public use, and are intended for some public service or for the development of the national wealth. The Court applied this provision to hold that, absent legislation passed by Congress, the Baguio Townsite Reservation shall belong to the public and exclusively for public purpose, and that the Wright Park, the Secretary's Cottage, the Senate President's Cottage, the Mansion House, and the public roads therein covered by the assailed CALTs shall remain for the benefit and enjoyment of the public.

• Native Title Claim Not Established — The NCIP described native title as the interests and rights of indigenous inhabitants in land, whether communal, group or individual, possessed under the traditional laws acknowledged by, and the traditional customs observed by, the indigenous inhabitants. The Court held that the respondents' claim of native title did not overcome Section 78 of the IPRA and the bar under Act No. 627 and Civil Reservation Case No. 1, because their rights were never recognized in any administrative or judicial proceeding prior to the effectivity of the IPRA.

• "The City of Baguio shall remain to be governed by its Charter and all lands proclaimed as part of its townsite reservation shall remain as such until otherwise reclassified by appropriate legislation: Provided, That prior land rights and titles recognized and/or acquired through any judicial, administrative or other processes before the effectivity of this Act shall remain valid: Provided, further, That this provision shall not apply to any territory which becomes part of the City of Baguio after the effectivity of this Act." — This is the controlling text of Section 78 of RA 8371, which the Court construed as excluding Baguio City and its townsite reservation from the IPRA and vesting reclassification solely in Congress.
• "Under the facts, the NCIP has no legal authority to issue CALTs or CADTs in favor of the subject properties included as Townsite Reservation areas in Baguio City." — This states the core ratio decidendi on the NCIP's lack of jurisdiction over lands within the Baguio Townsite Reservation.
• "The clear legislative intent is that, despite the enactment of the IPRA, Baguio City shall remain to be governed by its charter and that all lands proclaimed as part of Baguio City's Townsite Reservation shall remain to be a part of the Townsite Reservation unless reclassified by Congress. The NCIP cannot transgress this clear legislative intent." — This passage articulates the Court's reliance on legislative intent in construing Section 78 and rejecting the NCIP's authority.
• "To stress, private respondents' rights over the subject properties located in the Townsite Reservation in Baguio City were never recognized in any administrative or judicial proceedings prior to the effectivity of the IPRA law. The CALTs and CADTs issued by the NCIP to respondents are thus void." — This is the Court's ultimate holding that the CALTs and CADTs are void because the prior land rights exception did not apply.

• Republic vs. Fañgonil, 218 Phil. 484 (1984) — Controlling precedent. The Court relied on it to hold that claims within the Baguio Townsite Reservation not presented in Civil Reservation Case No. 1 were barred forever, and that the respondents' claims, based on possession since time immemorial, were similarly barred because their predecessors were necessarily served notice and should have filed their claims within the prescribed period.
• Cariño vs. Insular Government, 212 U.S. 449, 41 Phil. 935 — Cited in the Fañgonil discussion. The Court noted that Igorots who inherited their lands from their ancestors and had possession since time immemorial were allowed to avail themselves of registration under Act No. 496; however, the respondents in the present case did not establish a similar prior recognition of rights before the IPRA.
• Zarate vs. Director of Lands, 58 Phil. 156 — Cited in the Fañgonil discussion as an exceptional case where applicants proved visible occupation and lack of personal notice. The Court in Fañgonil held that Zarate could not be a precedent at a late hour, and the present Court relied on Fañgonil rather than Zarate to bar the respondents' claims.
• Camdas vs. Director of Lands, L-37782, Resolution of March 8, 1974 — Cited in the Fañgonil discussion. It held that the Baguio Court of First Instance has no jurisdiction to entertain land registration proceedings under Act No. 496 and the Public Land Law covering any lot within the Baguio Townsite Reservation, which was terminated in 1922.
• Archbishop of Manila vs. Barrio of Santo Cristo, 39 Phil. 1 (1918) — Cited for the rule under Act No. 627 that any landowner affected by the declaration of military reservations must register their titles within the period stated in the Land Registration Act; otherwise, such land rights would be considered barred.

• Article XII, Section 5, 1987 Constitution — Provides that the State shall protect the rights of indigenous cultural communities to their ancestral lands to ensure their economic, social, and cultural well-being. The NCIP relied on this provision, but the Court held that Section 78 of RA 8371 specifically excludes Baguio City and its townsite reservation from the IPRA's coverage.
• Section 78, RA 8371 (Indigenous Peoples' Rights Act of 1997) — The special provision providing that the City of Baguio shall remain governed by its Charter and all lands proclaimed as part of its townsite reservation shall remain as such until otherwise reclassified by appropriate legislation; prior land rights and titles recognized or acquired before the effectivity of the Act remain valid; and the provision does not apply to territories becoming part of Baguio after the effectivity of the Act. The Court applied this provision to void the NCIP-issued CALTs and CADTs.
• Section 8, RA 8371 — Provides for the right to ancestral lands of indigenous cultural communities and indigenous peoples. The NCIP cited this provision in granting the petitions, but the Court held that it did not authorize the NCIP to issue CALTs over lands within the Baguio Townsite Reservation absent prior recognition of rights before the IPRA.
• Rule XIII, Section 1, IPRA Implementing Rules — Provides that lands within the Baguio Townsite Reservation shall not be reclassified except through appropriate legislation. The Court cited this rule to reinforce that only Congress may reclassify the townsite reservation.
• Article 420, Civil Code — Defines property of public dominion as those intended for public use, such as roads, canals, rivers, torrents, ports and bridges constructed by the State, banks, shores, roadsteads, and others of similar character, and those which belong to the State, without being for public use, and are intended for some public service or for the development of the national wealth. The Court applied this provision to hold that the Baguio Townsite Reservation lands covered by the assailed CALTs belong to the public and the State.
• Section 32, Act No. 926 — Provides for free patents to native settlers who have continuously occupied and cultivated unreserved, unappropriated agricultural public land since 1 August 1890, or for three years prior to 1 August 1898, and who have been continuously since 4 July 1902 an occupier and cultivator of such land. The Court identified this as the remedy afforded to indigenous cultural communities for prior land rights.
• Section 62, Act No. 926 — Provides that whenever lands are set apart as town sites, the Chief of the Bureau of Public Lands may notify the judge of the Court of Land Registration that such lands have been reserved as a town site and that all private lands or interests therein within the limits described are to be brought within the operation of the Land Registration Act. The Court cited this provision in narrating the registration process for the Baguio Townsite Reservation.
• Act No. 627 — Governs military reservations and requires landowners affected by the declaration of military reservations to register their titles within the period stated in the Land Registration Act; otherwise, such land rights are barred. Section 3 provides that the certification by the clerk of court is conclusive proof of service of the notice. The Court applied this Act, through Fañgonil, to bar the respondents' claims.
• Act No. 496 (Land Registration Act) — The law under which private lands within the Baguio Townsite Reservation could be registered. The Court cited it in the registration history of the reservation and in the Fañgonil discussion.

Caguioa, Reyes, J., Jr., Lazaro-Javier, and Zalameda, JJ., concur.