Fianza seeks city control of 211 title validation, cites ‘disturbing’ observations

In a privilege speech on April 27, 2026, Councilor Peter Fianza urged the transfer of authority to validate remaining 211 title applications to the City Government of Baguio. He also called for the denial of new applications, the cancellation of titles without corresponding applications, and the recovery of lands covered by invalid 211 titles.
Fianza’s call followed what he described as “disturbing” observations in the validation process, which he said have delayed the resolution of decades-old issues involving 211 titles.
211 titles refer to land titles in Baguio City that originated from the reopening of Civil Registration Case No. 1, GLRO Record No. 211 which is a case filed in 1912 during the American colonial period to determine which lands within the Baguio Townsite Reservation could be privately owned.
A 1922 court decision declared most of the townsite as public land, barring unfiled private claims. However, subsequent court reopenings led to the issuance of titles later ruled invalid by the Supreme Court for lack of jurisdiction. These titles were declared null and void, though Presidential Decree No. 1271 allowed their validation under specific conditions, particularly for innocent third parties.
Based on data from the Department of Environment and Natural Resources-Cordillera (DENR-CAR) and the Land Registration Authority, there are more than 6,000 applications for validation, of which more than 3,000 titles already validated and 2,875 applications still pending validation.
“What we have observed from these records is irritating and also dangerous,” Fianza said.
Fianza noted that some titles declared invalid remain active at the Registry of Deeds (ROD) due to the absence of clear guidelines for their cancellation. These include expanded titles at Outlook Drive and Sto. Tomas Barangay which cover more than 67 hectares.
Also, ROD records show that transactions involving lands covered by 211 titles with pending applications are not being processed or are placed on hold due to the absence of clear guidelines on how to handle such cases.
Meanwhile, validation records reveal irregular patterns in approvals and documentation, alongside reported discrepancies and allegations of irregularities, possible procedural lapses, and fraudulent validations.
In 2024, DENR-CAR revealed that the validation of more than 2,000 211 titles may take up to 277 years as processing is limited to about eight applications annually due to budget and personnel constraints.
With decades-long delays caused by the aforementioned concerns, Fianza warned that many of the areas covered by unvalidated 211 titles are already occupied and covered by tax declarations and that continued delays in validation may result in full occupation and loss of opportunity for proper land use planning in the city. He stressed that prolonged inaction could undermine the city’s ability to integrate these lands into the Comprehensive Land Use Plan (CLUP).
To address the backlog, Fianza proposed the devolution of the validation of remaining pending applications to the city government, either through enabling legislation or through amendments to the City Charter.
Pending devolution, he urged the PD 1271 committee to allow the city to form a technical working group to review questionable validations and continue evaluating pending applications.
Fianza likewise requested deputization from the Office of the Solicitor General for the implementation of decisions denying applications for validation of 211 titles, and if feasible, cancellation proceedings for 211 titles without applications for validation and those with denied applications.
For proper classification to be used for public purposes, Fianza also appealed for the immediate identification of 211 titles without applications for possible classification as greenbelts, non-buildable areas, or for social housing.
He also requested from the validation committee and ROD the relevant records including inventories, application status, validation outcomes, and supporting documents needed to address issues in validation decisions.
Lastly, he recommended the endorsement of requests for investigation to the proper offices for the possible filing of appropriate cases involving questioned titles found to have been fraudulently or unlawfully secured.
The Baguio City Council, through Resolution 321-2026, adopted all the recommendations of Fianza. **Jordan G. Habbiling