The dispute regarding the 319-hectare parcel of land in Barangays Anahao, Canduyong, and Tubigon, commonly referred to as the Buyco Estate, traces its roots back to Charles Hankins, an American who allegedly owned the land. When he passed away in 1937, the land was inherited by his heirs, including his grandchildren Samuel and Edgar Buyco.
Seeking to formalize ownership, the Buyco brothers, who had acquired American citizenship in 1972 and 1975, filed an application for land registration in 1976, under the Land Registration Act, claiming ownership through inheritance and donation.
In 1985, the Regional Trial Court (RTC) granted their application, confirming their title to the land. This ruling was later upheld by the Court of Appeals in 1989, dismissing an appeal from the Director of Lands.
However, the legal battle took a drastic turn in Buyco v. Republic, G.R. No. 102666 (1992), when the Supreme Court reversed the lower courts’ decisions. The Court ruled that as American citizens, the Buycos were disqualified from owning land in the Philippines under Section 7, Article XII of the 1987 Constitution. Furthermore, the Supreme Court determined that they failed to prove the land was alienable and disposable (A&D), citing that the property was classified as pasture land, making it ineligible for private ownership under Commonwealth Act No. 141 (Public Land Act).
Despite this, the Buycos filed another land registration application in 1995, arguing that Samuel Buyco had reacquired Filipino citizenship. The RTC ruled in their favor in 2000, ordering the registration of the land in Samuel Buyco’s name.
However, the Court of Appeals overturned this decision in 2011, citing res judicata, a legal principle that prevents the relitigation of the same issue that has already been decided with finality.
The case reached the Supreme Court once again, and in Buyco v. Republic, G.R. No. 211702 (August 29, 2018), the High Court denied the Buycos’ petition, affirming the appellate court’s decision and stressing the lack of sufficient evidence proving the land was alienable and disposable. Notably, the Supreme Court dismissed the case without prejudice, meaning the Buycos were not permanently barred from refiling their application if they could present sufficient proof that the land is A&D and eligible for private ownership.
In 2021, President Rodrigo Duterte signed into law Republic Act No. 11573, which streamlined the process for securing free patents and made it easier to establish land as A&D. However, this law reportedly enabled private individuals—some of whom were not from Barangays Anahao, Canduyong, or Tubigon—to obtain land titles through free patent applications, further complicating the farmers’ claims over the Buyco Estate.
Romblon News Network has reached out to the Department of Environment and Natural Resources (DENR) regarding the exact status of the controversial land, but the agency has yet to respond.
Erratum:
In a previous version of this article, we omitted a crucial detail regarding the Supreme Court’s ruling in Buyco v. Republic, G.R. No. 211702 (August 29, 2018). While the Court denied the Buycos’ petition and affirmed the appellate court’s decision, it dismissed the case without prejudice. This means that the Buycos were not permanently barred from refiling their land registration application, provided they could present sufficient proof that the land is alienable and disposable (A&D) and eligible for private ownership.
We acknowledge this oversight and have since updated the article to accurately reflect the ruling. We regret any confusion this may have caused.
