Title
Santiago Abadilla vs. Florention Laureta, Dionisio Laureta, and Domingo Guillermo
Case
REGISTRO GENERAL NO. 3485
Decision Date
Mar 23, 1908
Dispute over land, irrigation dam, and ditch ownership; plaintiff claims damages from defendants' usurpation. Court orders restitution, indemnity, and new trial for damages.
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Case Digest (REGISTRO GENERAL NO. 3485)

Facts:

    Plaintiff’s Ownership and Description of the Real Property

    • The plaintiff, Santiago Abadilla, asserts ownership of a specific parcel of land located in the site of Tamdagan, municipality of Dingras, province of Ilocos Norte.
    • The property is defined by adjacent boundaries:
    • North – adjoining lands of Pedro Hernando and Andres Guerrero.
    • South – bordered by forested areas and lands owned by Florentino Laureta and Dionisio Laureta.
    • East – contiguous with lands of Dionisio Laureta.
    • West – adjacent to other parcels owned by the plaintiff.
    • In addition to the land, the plaintiff owns an irrigation system consisting of a ditch (zanja) and an associated dam (presa) that utilizes water from the Gasgas or Tamdagan River to irrigate not only the contested lot but also other nearby lands.

    Alleged Usurpation and Interference with Property Rights

    • In June 1903, defendant Florentino Laureta is alleged to have unlawfully taken possession of the disputed land, cultivating it with palay (rice) during 1903 and 1904.
    • In July 1903, Florentino Laureta, along with co-defendants Dionisio Laureta and Domingo Guillermo, allegedly seized control of the irrigation works by closing the zanja and its two smaller arms—using stones and earth—thereby disrupting the normal flow of water.
    • The closure of the irrigation system not only affected the disputed parcel but also deprived the plaintiff’s adjoining lands of necessary irrigation, resulting in the destruction of rice crops.

    Proof of Ownership and Possession

    • The plaintiff presented several public documents evidencing acquisitions of contiguous parcels that together form the property described in his claim. These documents include detailed descriptions of the boundaries, which correspond with the evidence shown in an accompanying map (Exhibit A).
    • The uninterrupted sequence of ownership is supported by the plaintiff’s acquiescence to these documents, with no substantial objection raised by the defendants regarding the contiguous nature of the parcels.
    • Testimonies from four long-time tenant farmers who had cultivated the land further substantiate the plaintiff’s continuous possession and right over the disputed property.

    Disputed Irrigation Works

    • The plaintiff asserts that the irrigation ditch and dam, besides serving his property, extend into areas commonly associated with other lot owners.
    • Evidence from documents (Exhibit B) and witness testimony indicates that the initial construction of part of the zanja was performed by Adriano Mata and Policarpo Nery, as officially recognized by a governmental concession and adjudication in 1970.
    • Defendant Dionisio Laureta acknowledged the role of Mata and Nery in the construction, albeit with reservations regarding the completion of the works.

    Claimed Damages and Relief Sought

    • The plaintiff claimed damages based on the loss of palay yield:
    • He quantified the production of the usurped land as 16 uyones annually, with an allegation of lost yield amounting to 100 uyones over the years 1903 and 1904.
    • Additionally, the disruption of irrigation to his adjacent lands was claimed to have caused further economic losses.
    • Relief was sought in two parts:
    • A condemnation against Florentino Laureta to restitute possession of the disputed land and indemnify the plaintiff for lost yield.
    • A subsequent condemnation against Florentino Laureta, Dionisio Laureta, and Domingo Guillermo to restore the irrigation works to their original condition and indemnify for damages incurred due to the usurpation.

Issue:

    Title and Possession

    • Whether the plaintiff is the rightful owner of the disputed land as evidenced by documentary and testimonial proofs.
    • Whether the contiguous parcels and their boundaries have been adequately established by the evidence presented.

    Legality of the Defendants’ Possession and Action

    • Whether defendant Florentino Laureta’s entry and cultivation of the land in June 1903 constituted an unlawful usurpation of the plaintiff’s property.
    • Whether the subsequent closure of the irrigation ditch and dam by the defendants amounted to an interference with the plaintiff's established rights over his land and its irrigation benefits.

    Adequacy of Evidence

    • The sufficiency of both documentary and witness evidence in establishing the plaintiff’s continuous possession and legal title.
    • The reliability of the defendants’ evidence regarding the origin and construction of the irrigation works, particularly the government concession title dating from 1970, which did not pertain to the disputed property.

    Determination of Damages

    • The appropriate method to quantify the losses incurred by the plaintiff as a result of the usurpation and interference with irrigation.
    • Whether the value of each uyon of palay should be fixed at the plaintiff’s stated values (either ten or five pesos), or determined anew in a subsequent trial.

Ruling:

  • (Subscriber-Only)

Ratio:

  • (Subscriber-Only)

Doctrine:

  • (Subscriber-Only)

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