Case Digest (G.R. No. 69002)
Facts:
Republic of the Philippines v. Amanda Lat Vda. de Castillo, et al., G.R. No. 69002, June 30, 1988, the Supreme Court Second Division, Paras, J., writing for the Court.
The petition is a Rule 45 petition for review on certiorari from the April 26, 1984 Decision of the then Intermediate Appellate Court (Court of Appeals) reversing the February 6, 1976 Decision of the then Court of First Instance (CFI) of Batangas, Branch VI, in Civil Case No. 2044.
In 1951 the late Modesto Castillo applied for registration of two parcels (Lots 1 and 2, Plan PSU-119166). An Original Certificate of Title No. O-665 was issued to him in 1952. After consolidation and subdivision of surrounding parcels, and following Modesto’s death, the heirs executed a deed of partition in 1960 and new Transfer Certificates of Title were issued to various members of the Castillo family covering Lots 1–9 (TCT Nos. T-21703, T-21704, T-21708, T-21712, T-21713, T-21718, T-21727).
The Republic filed Civil Case No. 2044 seeking annulment of the certificates of title covering Lots 1 and 2 and reversion of those lands to the State, alleging the lots formed part of Taal Lake and thus were public, unregistrable foreshore/shore lands. Defendants (the Castillos) pleaded that the government's action was barred by the prior registration decision, had prescribed, and was estopped; they asserted long and peaceful possession and invoked Article 778 (Law of Waters) to claim accretion and private ownership.
At trial the CFI (Relova, J.) found for the Republic and ordered cancellation of the original and subsequent titles, declaring Lots 1 and 2 public lands (Feb. 6, 1976). On appeal the Intermediate Appellate Court reversed and dismissed the complaint (Apr. 26, 1984). The Republic’s motion for reconsideration before the Court of Appeals was denied (Oct. 12, 1984), and the Republic filed the present petition to the Supreme Court.
The record contains extensive survey plans and expert testimony for the Republic: the 1923 Tanauan cadastral plan and the 1948 PSU-119166 relocation-verification plan annotated the disputed areas as foreshore/shoreline; Bureau of Lands geodetic engineers testified that monuments were submerged, points unidentifiable because under water, and that the lots were inundated in rainy seasons; verification/relocation surveys (including a 1962 relocation) and ocular inspection showed monuments washed out and evidence of shell and mud deposits. Local witnesses corroborated recurrent inundation, duck pens, and that occupants filled areas with shells and sand to make them habitable.
Private respondents introduced witnesses asserting long possession by the Castillo family and occupation by occupants engaged in duck raising and cultivation, contending the inundation was accidental and that accretion under Article 778 vested ownership in the private owners; they also urged res judicata because the title had been previousl...(Subscriber-Only)
Issues:
- Does the decision of the land registration court in the prior registration proceeding operate as res judicata to bar the Republic’s action to annul the certificates of title for Lots 1 and 2, when the lots are claimed to be foreshore/shore lan...(Subscriber-Only)
Ruling:
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Ratio:
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Doctrine:
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