Case Digest (G.R. No. 108065) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In Spouses Felix Baes and Rafaela Baes v. Court of Appeals and Republic of the Philippines (G.R. No. 108065, July 6, 1993), petitioners Felix and Rafaela Baes owned Lot 2958 in Pasay City, originally registered under TCT No. 10990. In 1962 the government excavated a canal across Lot 2958, which was then subdivided into Lots 2958-A (28,889 sq m), 2958-B (3,588 sq m) and 2958-C (452 sq m) under TCT Nos. 11041, 11042 and 11043. By Deed of Exchange dated June 20, 1970, the Republic took Lot 2958-B and transferred to Baes Lot 3271-A of equal area, later registered as TCT No. 24300. Meanwhile, petitioners successfully petitioned the Court of First Instance of Pasay City on January 15, 1968, to resurvey and subdivide Lot 2958-C and part of Lot 2958-A into Lot 1, Block 4, resulting in four new titles: TCT No. T-14404 (672 sq m), TCT No. T-14405 (826 sq m), TCT No. T-14406 (452 sq m) and TCT No. T-14407 (2,770 sq m). Lots T-14406 and T-14407 were later consolidated and subdivided into TC Case Digest (G.R. No. 108065) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Initial Acquisition and Canal Construction
- In 1962, the government excavated a canal on private Lot 2958 (33,902 sqm) to improve the Tripa de Gallina creek.
- Felix Baes acquired Lot 2958, registered under TCT No. 10990, then subdivided it into:
- Lot 2958-A (28,889 sqm) – TCT No. 11041
- Lot 2958-B (3,588 sqm) – TCT No. 11042 (entirely occupied by the canal)
- Lot 2958-C (452 sqm) – TCT No. 11043
- Deed of Exchange and Resurvey
- On June 20, 1970, the government and Baes executed a Deed of Exchange: Lot 2958-B for government’s Lot 3271-A (3,588 sqm), later TCT No. 24300.
- Soil from the canal filled the old creek bed. Baes petitioned (Jan. 12, 1968) for resurvey and subdivision of Lot 2958-C and part of Lot 2958-A, citing bearing and distance errors.
- Issuance and Consolidation of New Titles
- On January 15, 1968, the CFI of Pasay approved the resurvey-subdivision, canceling old TCTs and issuing:
- Lot 1-A, Blk. 4 (672 sqm) – TCT No. T-14404
- Lot 1-B (826 sqm) – TCT No. T-14405
- Lot 2958-C-1 (452 sqm) – TCT No. T-14406
- Lot 2958-C-2 (2,770 sqm) – TCT No. T-14407
- Lots 2958-C-1 and 2958-C-2 were consolidated and re-subdivided into four lots:
- Lot 1 (147 sqm) – TCT No. 29592
- Lot 2 (950 sqm) – TCT No. 29593
- Lot 3 (257 sqm) – TCT No. 29594
- Lot 4 (1,868 sqm) – TCT No. 29595
- Cancellation Proceedings
- In 1978, the Republic petitioned to cancel TCT Nos. 14405 and 29592–29595, asserting Lot 1-B overlapped filled-up Lot 3611 and that Lot 2958-C had been unlawfully enlarged.
- Baes did not oppose cancellation of TCT Nos. 29592, 29594, 29595; could not prove government used any portion of Lot 2 (TCT 29593). Trial court ordered cancellation of all contested titles, reinstating the original 452 sqm. parcel.
Issues:
- Whether upon abandonment of the old creek bed by artificial diversion, petitioners automatically acquired ownership of the filled-up bed under Article 461 of the Civil Code.
- Whether the June 20, 1970 Deed of Exchange constituted full and exclusive compensation, precluding any further claim by petitioners.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)