Cruz and Europa v. Secretary of Environment and Natural Resources

National Historical Society, Inc., p. 43 [1997]. [60] Id. [61] Id. at 43-44. [62] Tan, supra, at 47-48. [63] Id. at 48-49. [64] Cacho v. Government of the P.I., 28 Phil. 616, 625-627 [1914]; see also Ponce, The Philippine Torrens System, pp. 11-12 [1964]. In Philippine pre-colonial history, there was only one recorded transaction on the purchase of land. The Maragtas Code tells us of the purchase of Panay Island by ten Bornean datus led by Datu Puti from the Atis under Marikudo in the 13th century. The purchase price for the island was a gold salakot and a long gold necklace - Agoncillo, supra, at 25. [65] Constantino, supra, at 38. [66] Corpuz, supra, at 39. [67] Resettlement-- "bajo el son de la campana" (under the sound of the bell) or "bajo el toque de la campana" (Under the peal of the bell). [68] People v. Cayat, 68 Phil. 12, 17 [1939]. [69] Id. at 17, citing the Decree of the Governor-General of the Philippines, Jan. 14, 1887. [70] Agoncillo, supra, at 80. [71] Id. at 80. [72] Corpuz, supra, at 277-278. [73] Id. at 277. [74] Id., N.B. But see discussion in Cariño v. Insular Government, infra, where the United States Supreme Court found that the Spanish decrees in the Philippines appeared to recognize that the natives owned some land. Whether in the implementation of these decrees the natives' ancestral rights to land were actually respected was not discussed by the U.S. Supreme Court; see also Note 131, infra. [75] Tan, supra, at 49-50. [76] Id. at 67. [77] Id. at 52-53. [78] Id. at 53. [79] Id. at 55.