Case Digest (G.R. No. 97995) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In Republic of the Philippines (Director of Lands) v. Court of Appeals, G.R. No. L-61647, decided October 12, 1984, private respondents Benjamin Tancinco, Azucena Tancinco Reyes, Marina Tancinco Imperial and Mario C. Tancinco held Transfer Certificate of Title No. T-89709 over a fishpond in Barrio Ubihan, Meycauayan, Bulacan, bordering the Meycauayan and Bocaue rivers. On June 24, 1973, they applied to register three adjacent parcels (Lots 1, 2 and 3 of Plan PSU-131892) as accretion to their titled fishpond. The Bureau of Lands, through the Assistant Provincial Fiscal, opposed on April 5, 1974. The respondents withdrew Lot 3 on recommendation of the court-appointed commissioner and trial proceeded on Lots 1 and 2. On June 26, 1976, the Court of First Instance of Bulacan granted registration, holding those lots to be accretion by the gradual deposition of river sediments. The Republic of the Philippines appealed, and on August 19, 1982, the Court of Appeals affirmed in toto the l Case Digest (G.R. No. 97995) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Parties and Property
- Private respondents Benjamin, Azucena, Marina and Mario Tancinco owned a 12-hectare fishpond covered by TCT No. T-89709, situated in Barrio Ubihan, Meycauayan, Bulacan, along Meycauayan and Bocaue rivers.
- On June 24, 1973, they applied to register three adjacent parcels (Lots 1, 2 and 3 of Plan PSU-131892) totaling 41,375 sq.m. as accretions to their fishpond.
- Procedural History
- April 5, 1974: Assistant Provincial Fiscal filed opposition on behalf of the Bureau of Lands.
- March 6–7, 1975: Private respondents withdrew Lot 3 from the application; trial proceeded on Lots 1 and 2 only.
- June 26, 1976: CFI of Bulacan granted registration, finding Lots 1 & 2 natural accretions to TCT No. T-89709.
- July 30, 1976: Republic of the Philippines (Director of Lands) appealed to the Court of Appeals.
- August 19, 1982: CA affirmed the lower court decision in toto.
- October 12, 1984: Supreme Court granted certiorari to review whether the additions were natural accretions or artificial reclamations and whether the lots were registrable.
Issues:
- Nature of the Additions
- Whether Lots 1 & 2 arose by natural, gradual and imperceptible river accretion under Civil Code Article 457.
- Whether the accretion was man-made (dike extension/reclamation) and thus excluded from Article 457.
- Registrability and Public Domain
- Whether portions of the riverbed are part of the public domain and non-registrable under Land Registration Act.
- Whether the trial court and CA committed grave abuse by misapprehending facts and ignoring evidence of artificial reclamation.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)