Title
Delos Reyes vs. Municipality of Kalibo, Aklan
Case
G.R. No. 214587
Decision Date
Feb 26, 2018
A dispute over land claimed as accretion by the Peraltas, contested by Kalibo Municipality for public use, ruled as public domain due to lack of legal title.

Case Digest (G.R. No. 168486)
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)

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