Title
Santiago vs. Court of Appeals
Case
G.R. No. 109111
Decision Date
Jun 28, 2000
MWSS claimed ownership of land in San Mateo, Rizal, via prescription, opposing heirs contested. SC ruled MWSS as owner due to 30+ years of open, continuous possession; petitioners' titles excluded disputed land.
A

Case Digest (G.R. No. 109111)

Facts:

Carmelino M. Santiago, Montserrat M. Santiago, Nilda M. Iboleon, Belinda Manahan and Josefina M. Capinpin v. Court of Appeals and Metropolitan Waterworks and Sewerage System, G.R. No. 109111, June 28, 2000, Supreme Court First Division, Pardo, J., writing for the Court.

On July 22, 1980, Metropolitan Waterworks and Sewerage System (MWSS) filed with the Regional Trial Court (RTC), San Mateo, Rizal an application for registration of title under the Torrens system over eleven parcels of land in San Mateo, Rizal, described in several relocation plans and technical descriptions. MWSS alleged ownership through itself and its predecessors-in-interest (NAWASA and MWD), claiming open, continuous, exclusive and notorious possession under a bona fide claim of ownership dating from June 12, 1945; MWSS pointed to the burial of a 42-inch steel aqueduct pipeline beneath the subject strips that had been installed long before World War II.

On August 21, 1987 MWSS filed a second amended petition. On January 27 and October 24, 1988, oppositions were filed by Nilda Manahan Iboleon, Belinda Manahan and Josefina Manahan Capinpin, Montserrat M. Santiago, and Carmelino M. Santiago, respectively, each claiming ownership by virtue of Original Certificate of Title (OCT) or Transfer Certificates of Title (TCT) covering parcels adjacent to the strips where MWSS’ pipelines lie; they submitted their titles, related documents and testimony asserting that neither they nor their predecessors ever ceded possession to MWSS.

After hearings, the RTC, San Mateo, Rizal rendered a partial decision on November 26, 1990 in favor of the oppositors, ruling that (1) MWSS’ tax declarations merely furnished prima facie evidence of possession and did not prove ownership; (2) the titles presented by oppositors conclusively proved ownership and could not be collaterally attacked; (3) MWSS’ pipelines were buried and therefore its possession was not “open”; (4) MWSS discontinued pipe use after 1968 so possession was not “continuous”; and (5) MWSS’ use was merely tolerated and could not ripen into ownership. The RTC ordered dismissal of MWSS’ petition insofar as the oppositors were concerned and declared the oppositors owners of the strips located inside their titled properties.

MWSS appealed to the Court of Appeals (CA) by petition filed January 21, 1991. The CA, by decision promulgated July 22, 1992 (Alicia V. Sempio Diy, J., ponente), reversed the RTC in a new partial decision: it found the titles presented by oppositors described land adjoining but not overlapping the strips claimed by MWSS; it noted the pipelines were installed under untitled land before World War II, giving rise to a presumption of public land; it found oppositors failed to prove MWSS’ possession was merely tolerated and characterized much of oppositors’ testimony as hearsay; and it concluded MWSS acquired ownership by prescription, holding that the buried pipelines were nonetheless publicly known (e.g., signaled by “pilapils”) and that discontinuance of use did not constitute abandonment. The CA clarified on February 17, 1993 that one titled parcel of Carmelino Santiago adjoining a portion of the strips was excluded from its new partial decision.

Petitioners sought review in t...(Subscriber-Only)

Issues:

  • May this Court reexamine the conflicting factual findings of the RTC and the Court of Appeals in this Rule 45 appeal?
  • Did the Court of Appeals correctly find that MWSS acquired ownership of the subject strips by prescription and therefore was entitled to Torrens registration?
  • Do the transfer/original certificates of title presented by petitioners bar MWSS’ claim because they al...(Subscriber-Only)

Ruling:

  • (Subscriber-Only)

Ratio:

  • (Subscriber-Only)

Doctrine:

  • (Subscriber-Only)

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