G.R. No. 264179 - Singgit vs. People

This is a petition for review on certiorari under Rule 45 of the 1997 Rules of Civil Procedure challenging the Court of Appeals’ Decision dated November 24, 2003.
The dispute centers on a parcel of land covered by Original Certificate of Title (OCT) No. RO-487 (997), issued in 1927 in the names of Jose A. Fernando (married to Lucila Tinio) and Antonia A. Fernando (married to Felipe Galvez).
Upon the intestate death of the registered owners, their property remained undivided, leading to subsequent conflicts among their heirs regarding its partition.

Jose Fernando, Jr., Zoilo Fernando, Norma Fernando Banares, Rosario Fernando Tangkencgo, and the heirs of Tomas, Guillermo, Iluminada, and Germogena Fernando.
They claim that, as successors-in-interest, they are entitled to an equal (one-tenth) share of the property and seek partition so that they may develop or build their homes or businesses.
Petitioners rely on the original OCT as the basis of their title and claim that the failed implementation of decisions by previous generations should work in their favor.

Heirs of spouses Antonio Fernando and Felisa Camacho, represented by Hermogenes Fernando and respondent Leon Acuna.
They counter that portions of the property (notably Lot 1303) had already been subdivided and adjudicated based on a 1929 Cadastral Court Decision and other subsequent administrative rulings.
Respondents also allege that some parts of the property had been already sold or transferred, and they assert that the petition to partition is barred by laches due to their long and uncontested possession.

On April 17, 1997, petitioners filed a Complaint for Partition against the heirs of Germogena Fernando.
The defendants admitted to the allegations and did not contest the partition, offering to share in the expenses.
Subsequent interventions were made by respondent Leon Acuna (filed January 12, 1998) and later by Hermogenes Fernando (filed June 23, 1998) asserting intervening claims based on previous adjudications.
The trial court, post-pretrial conference and hearings, rendered its Decision on May 16, 2002, ordering the reversion of Lot 1303 (with exclusions for parts already sold or transferred) to the original owners and permitting partition among the petitioners as successors-in-interest.
The Court of Appeals reversed and set aside the trial court’s decision on November 24, 2003, dismissing the complaint.

Lot 1303 was allegedly subdivided by the November 29, 1929 Decision of the Cadastral Court into subdivisions (designated as Lots 1303-A, 1303-B, 1303-C, and 1303-D) with each portion assigned to different claimants.
Petitioners argue that the decision was never fully implemented (i.e., no titles were issued), and as the land remains registered in the name of their ascendants, it should revert entirely to them.
Respondents contend that decades of peaceful, uncontested possession of the subdivided lots bar any subsequent claim to re-titling, supported by the doctrine of laches.
Additionally, the issue of Sapang Bayan—a portion of the property whose origin (whether an accretion, riverbed, or dried-up creek) was unclear—is raised, with petitioners claiming ownership and respondents asserting its status as public land.

Evidence showed that Lot 1302 had been previously subdivided and titled to third parties based on the July 30, 1980 Decision of the Court of First Instance, thereby confining the dispute primarily to Lot 1303 and the Sapang Bayan portion.
Testimonies included:

Testimony by petitioner Elizabeth Alarcon and Norma Fernando asserting that their claim was limited to Lot 1303 and Sapang Bayan, and that the November 29, 1929 Decision was never executed.
Respondent Hermogenes Fernando’s detailed recollection of the 1929 Decision, the subsequent occupation of the respective lots by the designated parties, and the acknowledgment that the lots had been under uninterrupted possession.
Expert evidence from a Geodetic Engineer regarding the boundaries and the subdivision plan of the disputed property.

Petitioners base their claim on OCT No. RO-487 (997) as the best evidence of title, arguing that any failure to implement the previous subdivisional decision should not affect their rights of inheritance.
Respondents argue that:

The allocation executed by the 1929 Decision and the subsequent long-term possession establish an equitable bar against partition under the doctrine of laches.
The actual, uninterrupted possession of the subdivided lots by the assignees effectively prevents the petitioners from disturbing that status.
For Sapang Bayan, uncertainty concerning its origin (whether as an accretion or a dried-up creek bed) entails that it remains part of the public domain under relevant Civil Code provisions.

Whether the ownership of Lot 1303 (and by extension, the disputed portion known as Sapang Bayan) should revert to the descendants and heirs of the registered owners, given that the parcel remains under the title OCT No. RO-487 (997).
Whether the failure to implement the November 29, 1929 Decision of the Cadastral Court justifies petitioners’ claim that the entire lot, as registered, belongs to their ascendants.

Whether decades of uncontested possession and the acknowledgment by the parties of the subdivisional allotments bar the petitioners’ right to partition the property.
Whether the equitable principle of laches precludes the recovery or disruption of the established possession on Lot 1303.

Whether a title registered under the Torrens system, despite subsequent discrepancies in possession and division, is the definitive and best evidence of ownership against all adverse claims.
How the issue of implied trust, stemming from the erroneous inclusion of lots belonging to third parties, affects the petitioners’ claims.

Whether Sapang Bayan, whose factual origin as an accretion or as a dried-up creek bed remains unclear, is subject to private ownership or remains in the public domain under Articles 420 and 502 of the Civil Code.
Whether the principles of accretion can be applied in this case given the lack of clear evidence regarding its formation.