Case Digest (G.R. No. 4783)
Facts:
The case of Lucio Buzon y Javier vs. The Insular Government and the City of Manila revolves around a petition filed by Lucio Buzon y Javier on November 7, 1906, in the Court of Land Registration. The petitioner sought to have a parcel of land, measuring 2,619.18 square meters, registered. This land is located in Tondo, Manila, bounded by Calle Pavia to the north, the land of Dona Isidora Cristobal to the south, Calle Velazquez to the east, and Manila Bay to the west. The Insular Government and the City of Manila opposed the registration, with the Insular Government claiming that a portion of the land was covered by sea water during ordinary tides, thus categorizing it as public domain. The City of Manila contended that the measurements of the land were incorrect, asserting that the land included an extension of Calle Velazquez, which also belonged to the public domain.
The lower court found that Lucio Buzon had inherited part of the land from his parents, Leon Buzon and Ci...
Case Digest (G.R. No. 4783)
Facts:
Petition for Land Registration
On November 7, 1906, Lucio Buzon y Javier filed a petition in the Court of Land Registration to register a parcel of land in Tondo, Manila. The land was bounded by Calle Pavia (north), the land of Dona Isidora Cristobal (south), Calle Velazquez (east), and Manila Bay (west), with an area of 2,619.18 square meters.Oppositions by the Insular Government and the City of Manila
- The Insular Government opposed the registration, claiming that 1,549 square meters of the land were covered by sea water during ordinary tides and thus belonged to the public domain.
- The City of Manila opposed the registration, arguing that the measurements of the land toward Calle Velazquez were incorrect and included 15 square meters of public domain.
Petitioner’s Claim
Lucio Buzon y Javier claimed ownership of the land, stating that part of it was inherited from his parents, Leon Buzon and Cirila Javier, and the remainder was purchased from the heirs of Atanasio Buzon. He argued that the land described in his plan was correct and that the parcels claimed by the opponents were integral parts of his property.Historical Background of the Land
- The land was originally sold by the Augustinian fathers to Atanasio and Moises Buzon in 1872.
- After their deaths, the land was divided and transferred through inheritance and sales, eventually coming into the possession of Lucio Buzon.
- The land’s measurements had reduced over time due to natural causes, including the encroachment of sea water.
Evidence Presented
- Documentary evidence, including public instruments and oral testimony, supported Lucio Buzon’s claim of ownership.
- The court noted that the land had been in the possession of Lucio Buzon and his predecessors since 1872, satisfying the requirements for extraordinary prescription (30 years).
Issue:
Ownership of the Land Covered by Sea Water
Whether the portion of the land covered by sea water during ordinary tides belongs to the public domain or remains the private property of Lucio Buzon.Correctness of the Land Measurements
Whether the measurements of the land, particularly the portion adjacent to Calle Velazquez, were accurate or included public domain land.Validity of the Oppositions
Whether the oppositions filed by the Insular Government and the City of Manila had legal and factual basis.
Ruling:
The lower court ruled in favor of Lucio Buzon y Javier, adjudicating and registering the land in his name. The court held that:
The land, despite being partially covered by sea water during ordinary tides, remained the private property of Lucio Buzon. The encroachment of sea water was due to natural causes and did not transfer ownership to the public domain.
The measurements of the land were correct, and there was no evidence to support the claim that the land included public domain property.
The oppositions by the Insular Government and the City of Manila lacked legal and factual basis and were overruled.
The judgment was affirmed by the Supreme Court, as neither the Insular Government nor the City of Manila presented a bill of exceptions or assignments of error for review.
Ratio:
Private Ownership of Land Covered by Sea Water
The fact that land is covered by sea water during ordinary tides does not automatically make it part of the public domain. Ownership is retained by the private owner unless there is a legal basis for transferring it to the public domain.Extraordinary Prescription
Lucio Buzon and his predecessors had been in possession of the land since 1872, satisfying the 30-year extraordinary prescription requirement for ownership.Burden of Proof on Opponents
The Insular Government and the City of Manila failed to provide sufficient evidence to support their claims that the land belonged to the public domain or that the measurements were incorrect.Policy on Land Reclamation
The court emphasized the importance of private ownership and criticized the policy of the Insular Government and the City of Manila, which sought to infringe on private property rights without legal justification.