G.R. No. 169726 - Department of Budget and Management vs. Leones

Pedro P. Roxas applied for the registration of his inherited estate, the Hacienda de San Pedro Macati, under the Land Registration Act.
The hacienda, acquired by inheritance from his late father, Jose Bonifacio Roxas y Ubaldo, comprises four irregular parcels of land (labeled “A,” “B,” “C,” and “D”) totaling 1,761 hectares 51 ares and 5 centares.
The last tax assessment valued the entire property at P415,221.34, with portions assessed differently based on location: P59,904 for the part in Manila and P256,760 for that in the Province of Rizal.
Included in the estate is a building known as the “Casa-Quinta” (or “Casa de Ingenieros”), located in parcel “C,” covering 8,430 square meters and assessed at P98,557.34.
The hacienda is predominantly occupied by about 429 tenants, whose details were provided in the application.
Subsequent amendments to the application were made to correct technical descriptions and boundaries, notably a rectification reducing the original area by 1,446.70 square meters.

Julia Tuason opposed the registration of the hacienda on the grounds that for parcel “C” new boundary monuments had been erected without her consent, allegedly encroaching upon land she owned.
The Municipality of San Pedro Macati raised an objection asserting ownership over the municipal building and public school areas, emphasizing that these were long in the town’s possession and constituted public domain.
Alejandro and Consolacion Aguirre filed a separate opposition regarding the inclusion of two parcels in parcel “C” that they claimed were not part of the hacienda, particularly focusing on a building lot in Calle San Pedro.
Subpoenas and public notices were issued to adjoining property owners, leading to their respective oppositions and subsequent exceptions to the registration petition.

The primary controversy between Roxas and Tuason centered on the boundary line between their adjoining properties.

The petitioner claimed that the natural boundary was a creek (sapa) that had historically served as the limit despite its gradual decrease in width.
Tuason argued that the boundary was demarcated by straight lines drawn between existing old monuments and that these monuments, some of which were at a distance from the creek, defined her property.

Witness testimonies, including those of Rafael Rivera (the rent collector) and long-term tenants Tomas Medina and Santos Tenorio, supported the claim that the strip of land along the creek had long been regarded as part of the hacienda.
Evidence showed that in 1871 the creek had a width of about 4 Spanish yards, explaining why the monuments are now at some distance from the current bank.
There was no evidence that Julia Tuason’s land extended to the opposite bank of the creek, nor that she had taken steps to demarcate her property by survey as provided under law.
Legal provisions regarding accretion (Article 366 of the Civil Code) were cited as a basis for recognizing the gradual increase in the hacienda’s land due to the current’s effects.

On October 17, 1906, the lower court overruled the oppositions of Julia Tuason, the Municipality of San Pedro Macati, and the Aguirres (with respect to one of the parcels) and ordered the registration of the hacienda in favor of Pedro Roxas.
The court excluded from registration the parcel occupied by the municipal building, which was held to be subject to usufruct for public use.
The respondents excepted to the judgment and filed motions for a new trial based on alleged errors of law and evidence, but these motions were overruled.
Although Alejandro and Consolacion Aguirre filed a bill of exceptions, their appeal was later treated as abandoned due to failure to file the requisite brief within the prescribed time.

Whether the petition for registration of the Hacienda de San Pedro Macati by Pedro Roxas complied with legal requirements and accurately reflected the boundaries and extent of the estate.

Whether the natural limit constituted by the creek (sapa) is the proper demarcation line between Pedro Roxas’ hacienda and the land of Julia Tuason.
Whether the placement and removal of old and new boundary monuments affect the determination of the property line.

Whether the gradual accretion of land along the creek, in accordance with Article 366 of the Civil Code, rightfully belongs to the owner of the hacienda.

Whether the municipality’s claim on the land occupied by the municipal building and public school should preclude its registration to Roxas.
Whether the Aguirres’ claim regarding the second parcel included erroneously in the hacienda is sustainable, considering their failure to timely pursue their appeal.