Title
Marquez vs. Marquez
Case
G.R. No. 47792
Decision Date
Jul 24, 1941
Brothers Daniel and Gregorio Marquez disputed water rights over adjoining lands. A court-approved compromise granted equitable water usage, but Gregorio violated it by constructing a dam. The court upheld enforcement of the compromise but invalidated orders beyond its scope.

Case Digest (G.R. No. 47792)
Expanded Legal Reasoning Model

Facts:

  • Background and Land Dispute
    • The controversy involves three contiguous parcels of land as shown in Plan Annex A:
      • The first parcel on the north owned by defendant Gregorio Marquez (formerly Severo Jurado).
      • The second parcel on the south owned by plaintiff Daniel Marquez.
      • The third parcel also on the south and adjoining the second, owned by defendant Gregorio Marquez.
    • A dispute arose between the two brothers regarding the distribution and use of waters flowing from the northern parcel to the southern parcels.
  • The Compromise Agreement
    • The parties settled their dispute in Civil Case No. 3832 by entering into a compromise agreement, which was subsequently approved by the court and incorporated into its judgment.
    • Key stipulations of the compromise included:
      • Adjudication of land titles:
        • Gregorio Marquez was given full title to specific portions of the property identified on Plan Annex A (including the terrain occupied by a canal and designated lots).
ii. A small portion adjacent to the east side of a particular roadway was awarded exclusively to Daniel Marquez.
  • Construction and specifications for a dam:
    • Gregorio Marquez was obligated to build a concrete dam with iron reinforcements along specified points on the canal (points marked with numbers 2 and 3 and within a delineated circle on the plan).
ii. The dam was to have a height of one (1) foot above ground level and extend seventy (70) centimeters below ground, with a thickness of four (4) inches. iii. Its purpose was to prevent water from Daniel Marquez’s parcel from flowing into Gregorio Marquez’s canal during the days allocated to Daniel. iv. The dam was to be constructed on or before April 30, 1937.
  • Division of water usage rights:
    • Daniel Marquez was granted exclusive use of the waters on Mondays, Tuesdays, Wednesdays, and Thursdays.
ii. Gregorio Marquez was granted exclusive use of the waters on Fridays, Saturdays, and Sundays. iii. Specific directions were provided regarding the closing of canals at marked points in red ink on Plan Annex A to ensure proper water distribution. iv. The agreement detailed the timing for commencement of water enjoyment (7 a.m. on the respective days for each party).
  • Other provisions:
    • The cancellation and reissuance of a land title certificate to reflect Daniel Marquez as the sole owner of part of the property.
ii. Agreement that certain expenses, such as subdivision costs and issuance of new certificates, be borne by the respective parties in proportion to their interests. iii. A clause relating to granting equivalent rights on water usage effects from an upland parcel previously belonging to Severo Jurado.
  • Subsequent Alleged Violation and Court Proceedings
    • Plaintiff Daniel Marquez filed a motion in Civil Case No. 3832 alleging that defendant Gregorio Marquez had violated the compromise by constructing a dam at point X on Plan Annex A.
      • The constructed dam was alleged to have intercepted and prevented the free flow of waters from the northern property to Daniel Marquez’s southern property.
    • The trial court conducted an ocular inspection and rendered an order directing:
      • Defendant Gregorio Marquez to open the dam during the days (Monday to Thursday) when Daniel Marquez was entitled to exclusive water use.
      • Defendant to comply with the water-sharing provisions without, however, closing the right of way existing on the designated northern and southern strips related to the compromise.
    • Defendant Gregorio Marquez challenged the order, contending:
      • The lower court had jurisdiction only to enforce the terms of the compromise as originally agreed.
      • Any modification or addition—such as ordering that a right of way remain open—was beyond the scope of the compromise enforcement and required an independent action.

Issues:

  • Jurisdiction and Scope of Enforcement
    • Whether the trial court had the authority to enforce and, in certain respects, alter the precise terms of the compromise agreement when addressing the alleged violation by the defendant.
    • Whether the court’s additional order (directing that the right of way must not be closed) exceeded its jurisdiction, thereby constituting a new matter not covered by the compromise.
  • Validity and Application of the Special Judgment
    • Whether the special judgment order requiring the defendant to open the dam during the plaintiff’s designated water use days was properly enforced.
    • Whether the act of building the dam by the defendant amounts to a violation (and potential contempt) of the court’s order based on the compromise agreement.
  • Procedural Concerns
    • Whether the trial court’s action to settle the entire controversy in a single proceeding was appropriate, considering that some issues (such as the right of way) might constitute a separate cause of action.

Ruling:

  • (Subscriber-Only)

Ratio:

  • (Subscriber-Only)

Doctrine:

  • (Subscriber-Only)
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