G.R. No. L-6996; January 29, 1913
Municipality of Luzuriaga vs. The Director of Lands and the Roman Catholic Bishop of Jaro

FACTS

The Municipality of Luzuriaga (formerly Nueva Valencia) filed two consolidated land registration cases (Nos. 5829 and 5830) concerning adjoining parcels of land. For the parcel in case No. 5829, used as a municipal cemetery, the municipality acquired title by exchange in 1907, with evidence of occupation for about thirty years. For the parcel in case No. 5830, used as a public market and cockpit site, the municipality had occupied and administered it as owner for about forty years. The Director of Lands opposed the registration of the market/cockpit parcel, arguing (1) that land used for such purposes is presumed to be State land requiring an express grant, and (2) that the land is part of a public square and thus inalienable.

ISSUE

Whether the Municipality of Luzuriaga is entitled to registration of title over the parcel of land used as a public market and cockpit, based on a presumed grant from the State.

RULING

Yes. The Supreme Court affirmed the lower court’s decision registering title in favor of the municipality for both parcels. Regarding the market/cockpit parcel, the Court held that the municipality’s long, undisturbed, and unchallenged use of the land for public purposes that address a public necessity (like a public market) gives rise to a presumption of a grant from the State in its favor. The Court rejected the argument that such a presumption applies only to lands used for a courthouse or school, extending it to municipal markets as a public necessity in many localities. The claim that the land was part of a public square was not supported by the evidence, as the lower court found it was separated from the square by a street and had been occupied by market structures for decades.