G.R. No. L-43105 - Republic vs. Court of Appeals

Two petitions for review were consolidated, both arising out of the same Land Registration Case (LRC No. N-283, Laguna).
The petitions challenge a decision of the defunct Court of Appeals which set aside the trial court’s judgment and ordered the registration of a parcel of land in favor of Santos del Rio.
Petitioner Director of Lands contends that the land is part of the public domain and, thus, not subject to registration; meanwhile, private oppositors assert that they reclaimed the land through long-term possession and even by “dumping duck egg shells” on it.

The disputed lot measures 17,311 square meters and is located near Laguna de Bay, approximately 20 meters from its shore in Barrio Pinagbayanan, Pila, Laguna.
Originally purchased by Benedicto del Rio from Angel Pili on April 19, 1909, the transaction was evidenced by a public deed of sale recorded with the Registry of Deeds of Sta. Cruz, Laguna.
The land was declared for tax purposes in 1918, with realty taxes consistently paid from 1948 onward.
Upon Benedicto del Rio’s death in 1957, his heirs extrajudicially partitioned the estate, with Santos del Rio inheriting the subject parcel.

Santos del Rio filed an application for registration of the parcel on May 9, 1966.
Private oppositors, who previously obtained permission from Santos del Rio to construct duck houses on the land and later violated their agreement by constructing residential houses, opposed his registration application.
As a result of a dispute, Santos del Rio initiated an ejectment suit against these oppositors in 1966.
Simultaneously, during the mid-1960s, private oppositors filed their own sales applications with the Bureau of Lands while also opposing Santos del Rio’s application.
The Court of First Instance of Laguna dismissed Santos del Rio’s application, but the Court of Appeals later reversed this decision, ordering registration in favor of Santos del Rio.

The Director of Lands argued that a part of the land, being covered by water four to five months a year, constituted the lake bed or foreshore of Laguna de Bay and was thus part of the public domain.
Private oppositors claimed they had reclaimed the land and maintained possession for over twenty years.
The petitioners’ positions raised two major questions: (a) whether the land falls under the public dominion, and (b) whether Santos del Rio holds a registerable title.

Santos del Rio’s evidence of title included a public instrument of sale in favor of his father, tax declarations dating from 1918, and tax receipts issued from 1948 onward.
The Court of Appeals found that Santos del Rio, tracing his title through his father, had maintained open, continuous, public, peaceful, exclusive, and adverse possession of the property since April 19, 1909.
The possession was further characterized as being in the concept of owner with just title and in good faith, satisfying the requirements for acquisitive prescription.

Whether the parcel of land is public by nature—specifically, whether its partial submersion due to seasonal rains qualifies it as part of the lake bed or foreshore of Laguna de Bay and hence public domain, rendering it not registerable as private property.

Whether Santos del Rio has established a registerable title to the land through evidence of a valid title, continuous possession, and fulfillment of the requirements for acquisitive prescription under the Torrens System and applicable land laws.