G.R. No. 47683 - El Gobierno de las Islas Filipinas vs. Gomez

The dispute involves numerous parties: the Government of the Philippine Islands (solicitante y apelado) and various private claimants (Consolacion M. Gomez, Vicente and Lazaro Ramos, heirs of Mariano Urrutia, Nazario Ponce, Vicente Lara, Pilar Santos, Claro Reyes Panlilio, Juan Nolasco, Victoriana Feliciano, among others).
The controversy centers on several parcels recorded in the Catastro No. 48 of Manila, with subdivisions and boundaries depicted in different plans (e.g., piano Bsd-1720, piano Psu-91168, Exhibit X, and Exhibit X-1).

Initially, a set of 268 lots were presented in the cadastral records, with Consolacion M. Gomez and other parties claiming ownership of portions of these lots.
At Consolacion M. Gomez’s request, the original plan was amended (resulting in piano Bsd-1720) so that its boundaries corresponded with those shown within red-lined areas in Exhibit X.
Subsequent plans and markings (using various ink colors such as red, black, violet, green, yellow, moreno, and blue) were used by different claimants to designate the specific parcels they claimed.

June 10, 1931 – The Director of Terrenos claimed as public domain the parcels corresponding to lots 12, 13, and 14 (block 2796) as shown in both piano Bsd-1720 and Exhibit X.
June 21, 1932 – Vicente Ramos filed a claim for parcels designated as lots 1, 2, and 3 in his piano Psu-91168, overlapping with the areas indicated in piano Bsd-1720 and Exhibit X.
July 27, 1933 – The Director of Terrenos further claimed lot 3 from piano Psu-91168 and Exhibit X as public domain.
August 8, 1933 – In opposition to the Director and Vicente Ramos, Consolacion M. Gomez claimed parcels described in piano Psu-91168 (lots 1 and 3) and those marked as lots 4 and 5 in Exhibit X.
Additional month-later claims were filed by:

Paulina Urrutia and her coherederos, asserting rights over portions of lots 1 and 3.
Nazario Ponce and Vicente Lara, claiming parts of lots 2 and 3.
Pilar Santos, regarding portions of lots 1 and 3.
Claro Reyes Panlilio, asserting a claim over a part of the lots claimed by Pilar Santos.
Juan Nolasco, asserting claim over portions of lots 2 and 3.
Victoriana Feliciano (succeeded by her children and siblings) claimed the western portion of lot 1, corresponding to areas in both piano Bsd-1720 and marked in blue in Exhibit X.

To focus efforts against the Director’s reclamations, all claimants except Juan Nolasco settled among themselves regarding internal differences, as graphically summarized in Exhibit X-1.

Prior to 1882, the appellants (or their ancestors) had occupied and possessed the land; however, due to gradual and then rapid erosion by the sea, the plots were entirely submerged.
Approximately 37 years later (circa 1919), new land emerged in place of the lost parcels. Claimants attempted to reoccupy these parcels but were denied access by the officials of the Office of Terrenos.
The emergence of these new parcels was attributed to various reclamation works undertaken by the Government, including:

Closure of a canal near a prominent landmark to prevent further erosion.
Construction of a recreation field serving as a dike.
Extension of drainage tubes in Tondo to deposit sediments and other fill materials.
Dredging operations which, between 1933 and 1938, placed significant quantities of sand and earth (up to 18 million cubic meters, with 6 million actually used) onto these areas.

The Government maintained strict control over the occupation of these reclaimed parcels, requiring prior authorization for every occupation.

The trial court, after examining the evidence, declared that the parcels (the lots as shown in the various plans) were property of the Government of the Commonwealth of the Philippines.
Most claimants, except Juan Nolasco and Claro Reyes Panlilio, appealed the decision.
Consolacion M. Gomez and the other appellant parties argued a series of errors including:

Failure of the trial court to recognize fully identified lands and proven title by the claimants.
Erroneous findings that reclamation occurred solely due to Government works.
Incorrect application of abandonment and prescription doctrines due to lack of defensive acts such as the construction of protective walls.
Denial of motions for a new trial.

The only document presented to support private ownership was a sale deed dated November 11, 1871 (Exhibit 1Gomez), which did not meet the requirements for demonstrating continuous, adverse, public, and peaceful possession necessary for instituting a claim by prescription.

The Government demonstrated a need for the parcels for the construction of the North Harbor.
It relied on the evidence of extensive reclamation works and the provisions of the 1866 Law on Waters, which lays out that land gained from the sea through state-sanctioned works is deemed public property.

Whether the new parcels that emerged after the original land was lost to the sea (post-1882) can be considered as continuing the private ownership of the appellants’ ancestors.
Whether the reclamation resulting from Government engineering works transformed the nature of the land’s title, thereby rendering it public property despite previous private possession.

Whether the claimants sufficiently demonstrated continuous, public, peaceful, and adverse possession required to claim title by prescription.
Whether the single documentary evidence (the 1871 sale deed) provided adequate identification and proof of the precise boundaries and the extent of the land once owned by the appellants’ ancestors.

Whether the extended period of inaction (from 1919 to 1927) by the appellants amounted to an abandonment of rights, thereby facilitating the Government’s claim by prescription.
Whether the claimants’ failure to mark or enclose the land (e.g., by building walls) contributed to the inference of abandonment.

Whether the provisions of the Law on Waters of August 3, 1866, which grant title over lands reclaimed by authorized works, should be applied to declare the disputed parcels as Government property.
Whether precedents such as Lamprea vs. Director of Terrenos and Gobierno de las Islas Filipinas vs. Cabangis, which held analogously that reclaimed lands are state property, apply in this case.