Case Digest (G.R. No. 168486) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In Josephine P. Delos Reyes and Julius C. Peralta, represented by their Attorney-in-Fact J.F. Javier D. Peralta, petitioners, versus the Municipality of Kalibo, Aklan, its Sangguniang Bayan and Mayor Raymar A. Rebaldo, respondents, the controversy involves a disputed area of accretion adjacent to Lot No. 2076 of the Kalibo Cadastre. Originally covered by OCT No. 24435 in the name of Ana O. Peralta, the property passed to her brother Jose Peralta, who secured TCT No. T-5547 (1975) and later subdivided it into Lots 2076-A (TCT No. 6166) and 2076-B. Accretion purportedly added to the shoreline was first taxed under Ambrocio Ignacio’s name in 1945, who executed a quitclaim in Jose’s favor in 1955. Upon Jose’s death, Lot 2076-A transferred to his son Juanito Peralta (TCT No. T-13140, 1983), while the accretion was separately declared for taxation in the names of Juanito, Javier Peralta, Josephine delos Reyes, and Julius Peralta. In 1992, the Municipality of Kalibo began converting ap Case Digest (G.R. No. 168486) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Peralta Family and Title History
- Lot No. 2076 of the Kalibo Cadastre (101,897 sq.m.) was covered by OCT No. 24435 in the name of Ana O. Peralta. Upon her death, it passed to her brother Jose Peralta, who secured TCT No. T-5547 (1975) and subdivided it into Lots 2076-A (retained) and 2076-B (sold). Lot 2076-A was re-registered under TCT No. 6166 on November 17, 1975.
- Alleged accretion on Lot 2076 was first taxed under Tax Declaration No. 6466 (1945) in the name of tenant Ambrocio Ignacio, who executed a quitclaim to Jose for ₱70.44 (1955). Upon Jose’s death, Lot 2076-A was transferred to his son Juanito (TCT No. T-13140, 1983), while the accretion area was placed under Tax Decls. Nos. 21162-A to 21165-A in the names of Juanito, Javier, Josephine, and Julius.
- Municipality Project and Procedural History
- The Municipality of Kalibo, through its mayor and Sangguniang Bayan, planned to convert approximately four hectares of the accreted area into a garbage dumpsite. Juanito, representing his siblings, protested in letters dated November 10, 1992, and October 2, 1997, without success. The municipality built retaining walls (1996), structures (1997–1998), and fencing, relying on a DENR ECC and the assertion that the land was public domain.
- On January 26, 1998, the Peraltas filed a complaint for quieting of title over the accreted parcels. The RTC (Branch 6, Kalibo) ruled in their favor on February 22, 2005, declaring the parcels accretions and ordering cessation of dumpsite occupation. The CA reversed on September 28, 2012; denied reconsideration on August 28, 2014; and the Peraltas elevated the case to the Supreme Court.
Issues:
- Whether the Court of Appeals erred in reversing the RTC’s declaration that the subject parcels are accretions and not part of the public domain.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)