Mapa vs Insular Government

Mapa vs Insular Government G.R. No. L-4195, Feb. 18, 1908 Syllabus 1. AGRICULTURAL PUBLIC LANDS DEFINED. – The phrase “agricultural public lands” defined by the act of Congress of July 1, 1902, which phrase is also to be found in several sections of the Public Land Act (No. 926), means those public lands acquired from Spain which are neither mineral nor timber lands.

Facts: - The petitioner sought to have registered a tract of land of about 16 hectares in extent, situated in Iloilo. - From the evidence adduced it appears that the land in question is lowland, and has been interruptedly, for more than 20 years, in the possession of the petitioner and his ancestors as owners and the same has been used during the said period, and up to the present, as fish ponds, nipa lands, and salt deposits. The witnesses declare the land is far from the sea, the town of Molo being between the sea and the said land. - The claim of the Atty. General seems to be that no lands can be called agricultural lands unless they are such by their nature. He claims that it is not an agricultural land and therefore, cannot be disposed of nor can be allowed for homestead. - Judgment was rendered in favor of the petitioner and the Government has appealed. - A motion for a new trial was made and denied in the court below - The decision of the court was based upon Act No. 926 Section 54, par. 6 which provides that “ All persons who by themselves or their predecessors in interest have been in the open, continuous, exclusive, and notorious possession and occupation of agricultural public lands, as defined by said Act of Congress of July 1, 1902, under a bona fide claim of ownership except as against the Government, for a period of 10 years next preceding the taking effect of this Act, except when prevented by war, or force majeure, shall be conclusively presumed to have performed all the conditions essential to a Government grant and to have received the same, and shall be entitled to a certificate of title to such land under the provisions of this chapter. Issue: Whether or not the land in controversy is agricultural land within the meaning of Act. No. 926 Ruling: Yes - The phrase “agricultural public lands” defined by the Act of Congress of July 1, 1902, which phrase is also to be found in several section of the Public Land Act (No. 926), means those public lands acquired from Spain which are neither mineral nor timer lands.

Q: what lands are agricultural in nature? A: the Atty. General himself says that “ the most arid mountain and the poorest soil are susceptible of cultivation by the hand of man.”