Facts:

The case revolves around Domingo Banatao, Doroteo Banatao, Francisco Banatao, and Arsenio Banatao (plaintiffs and appellees) versus Salvador Dabbay and Jacinto Tuliao (defendants and appellants). The case was decided on September 23, 1918. The dispute centers on the ownership of a land parcel located in the sitio of Fugu, barrio of Malabbad, in the Province of Cagayan. The plaintiffs filed a suit in the Court of First Instance seeking a judicial determination of ownership and possession of a strip of land spanning 12 hectares, 86 ares, and 20 centares, which is claimed to be encroached upon by defendant Salvador Dabbay. In earlier proceedings, the defendant Tuliao disclaimed ownership, making him irrelevant for the appeal.

The background reveals that approximately 40 to 50 years prior, a new island named Fugu emerged in the Cagayan River. Juan Banatao, an ancestor of the plaintiffs, initially established himself at the northern part of this island. Over time, the river's ch

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Facts:

Background and Formation of the Island

• A new island, known locally as Fugu (meaning “island”), emerged in the Cagayan River about forty or fifty years ago near the disputed area.
• The formation of this island resulted from natural river processes, where alluvial deposits created new land while subsequent changes in the river’s course altered its physical character.
• Originally, the island was separate; however, following the abandonment of an eastern branch of the river, it became terrestrially connected with the adjacent mainland while retaining its historical name.

Possession and Title History

• An ancestor of the plaintiffs, Juan Banatao, initially settled on the northern end of the island soon after its formation.
• Other settlers, including individuals named Quienes, occupied separate strips of the island, predominantly on its southern part.
• In 1894, Jacinto Banatao, son of Juan Banatao, procured a possessory information, entered in the property register, indicating possession of the land and suggesting a title equivalent to that acquired by composition with the State.
• Continuous and uninterrupted possession by the plaintiffs and their predecessors in interest is evidenced from before 1881, thereby contributing to the perfection of their title.

Accretion and Erosion Dynamics

• Over time, the river’s activity led to significant changes in the island:
• The southern portion experienced erosion as the current gradually carried away the deposits previously occupied by non-Banatao settlers.
• In contrast, the northern and northwestern portions underwent accretion as alluvium was deposited, thereby enlarging the area under Juan Banatao’s occupation.
• The ongoing process of accretion significantly increased the land area held by the plaintiffs, who claim that the total area acquired by accretion amounts to 213 hectares, 36 ares, and 82 centares.

The Disputed Parcel and Defendant’s Claim

• The particular property in dispute is a strip extending east and west, covering an area of 12 hectares, 86 ares, and 20 centares, as indicated by the defendant Salvador Dabbay’s exhibit.
• Defendant Salvador Dabbay bases his claim on ownership or alleged long-term possession of a parcel on the east side of the abandoned eastern bed of the Cagayan River.
• The trial court, however, established that the river had not shifted gradually to the west but had abandoned its old eastern channel entirely, undermining Dabbay’s claim of accretion to his property.

Procedural History and Judicial Proceedings

• The plaintiffs initiated the action seeking judicial determination of ownership of the land and recovery of possession from the defendants, also claiming damages and costs.
• The Court of First Instance rendered a judgment in favor of the plaintiffs, affirming their title based on long possession, accretion, and the possessory information.
• On appeal, procedural issues such as the timing of the motion for a new trial and the subsequent bill of exceptions resulted in the appellate court limiting its review to issues of law only.
• The trial court took judicial notice of facts such as the navigability of the Cagayan River, a point later assailed by the appellants but upheld by the appellate decision.

Issue:

Validity of the Plaintiffs’ Claim to Ownership by Accretion

• Whether the plaintiffs’ continuous possession, bolstered by the possessory information and state grant, properly perfected their title even in the light of the island’s natural changes.
• To what extent the process of accretion—characterized by erosion on the southern end and deposition on the northern end—supports the plaintiffs’ claim over the disputed parcel.

Application of Legal Provisions and Judicial Notice

• Whether the court was correct in taking judicial notice of the navigability of the Cagayan River, despite the absence of an explicit reference to navigability in section 275 of the Code of Civil Procedure.
• How Articles 371 and 366 of the Civil Code along with relevant provisions of the Law of Waters (Articles 83 and 84) apply to the ownership of naturally accreted lands in this case.

Relevance of Prior Judgment and Res Judicata

• The impact of the previous judgment from the Court of First Instance—entered in favor of Salvador Dabbay in a related action concerning possession—on the current ownership dispute.
• Whether the defendant’s reliance on the res judicata doctrine and his title claim based on the earlier judgment conclusively bars the plaintiffs’ claim to the land in controversy.

Ruling:

• (Subscriber-Only)

Ratio:

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Doctrine:

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