‘Contested 211 titles cover over a fifth of Baguio’

Councilor Peter Fianza has warned that more than 1,100 hectares of land in Baguio City, equivalent to over one-fifth of the city’s total land area, are covered by so called 211 titles, many of which remain active in government records despite being denied validation.
Fianza raised the concern during the Baguio City Council’s Regular Session on July 21, 2025, citing unresolved conflicts and the lack of formal cancellation proceedings as a continuing source of legal and administrative complications.
The councilor stated that the conflict between the current occupants of lands and individuals holding 211 titles continues because even if such titles are no longer legally valid, they remain active or recorded in the Registry of Deeds (ROD).
He further explained that titles that were denied validation are not automatically removed from the records because the process to cancel or nullify them requires official action by the office of the Solicitor General. Without such intervention, even disapproved or expired titles stay active in the ROD, he said.
211 titles refer to those that were subject of the Civil Reservation Case No. 1, GLRO Record No. 211. This case was initiated in 1912 to settle private land claims.
The land title controversy began when most lands within the Baguio Townsite Reservation were declared public property under this case. Republic Act No. 931 allowed reopening of cadastral cases, leading the Court of First Instance to award parcels of land to individuals. However, the SC nullified this ruling on July 31, 1973.
Consequently, former President Ferdinand Marcos issued Presidential Decree No. 1271, voiding all titles issued under GLRO Record No. 211, except those issued before the SC decision, and provided a 90-day period for eligible title holders to file validation petitions, expiring on March 22, 1978. Subsequent extensions were granted under PD 1311 and PD 1651.
During the city council’s session on June 3, 2024, Benjamin Ventura, OIC Asst. Regional Director for Technical Services of DENR-CAR, explained that despite the SC decision, PD 1271 introduced a presumption that some of these titles might have been regularly processed. He said PD 1271 requires these titles to undergo a validation process instead of being automatically canceled.
Meanwhile, Engr. Leandro De Jesus of the City Environment & Natural Resources Office (CENRO) said it may take 277 years to complete the validation of these over 2,000 derivatives of 211 titles as budget constraints and personnel shortage had limited the processing to eight applications per year.
Based on data from DENR-CAR, there are approximately 6,000 derivative titles with applications for validation. Of which, 2,219 remain unvalidated. In comparison, the Land Registration Authority (LRA) reports 6,664 derivative titles with applications for validation, with 3,789 titles already validated and 2,875 applications still pending validation.
Fianza clarified that the city government had previously expressed its opposition to allowing a new round of validation since it may create more complications and legitimize claims that should no longer be entertained.
During the June 3, 2025 regular session, Atty. Brain Masweng, OIC of the National Commission on Indigenous Peoples (NCIP) Legal Affairs Office, said the NCIP has significant concerns regarding the derivatives of the 211 titles because there are ancestral land claimants opposing these title holders as their claims overlap with the latter’s titles.
He cited Department of Environment and Natural Resources (DENR) Administrative Order No. 2 which states that ancestral land claims should be prioritized over Free Patent or Townsite Sales Applications.
The city council deferred action on the matter to allow the invitation of concerned offices, including the ROD and the DENR, to a forum during one of its upcoming regular sessions. **Jordan G. Habbiling