Case Summary (G.R. No. L-25176)
Petitioner
Elsa Degayo, heir to Lot No. 861 (36,864 sqm), alleges that 52,525 sqm of newly exposed land along the former riverbed accreted to her title by inheritance and continuous possession since 1954.
Respondents
Cecilia Magbanua-Dinglasan, Johnny Dinglasan, Asuncion Magbanua-Porras, Mariano Magbanua, Pascualito Magbanua and Amado Magbanua Jr., registered owners of Lot No. 7328 (153,028 sqm), claim the disputed area is abandoned riverbed belonging proportionately to them under Civil Code Article 461.
Key Dates
• 1984 – Respondents filed Civil Case No. 16047 against Degayo’s tenants for recovery of abandoned riverbed.
• 1996 – RTC Branch 27 rules for respondents; decision becomes final and executory in 1999.
• 1996 – Degayo’s separate Civil Case No. 18328 filed in RTC Branch 22; decision in her favor.
• 2005–2006 – Court of Appeals reverses RTC Branch 22, holds res judicata, deems area abandoned riverbed.
• April 6, 2015 – Supreme Court resolves Rule 45 petition, applying the 1987 Constitution.
Applicable Law
• 1987 Constitution of the Philippines (decision after 1990)
• Civil Code Article 461 (abandoned riverbeds)
• Rules of Court, Rule 39 Sec. 47 (res judicata – claim preclusion and issue preclusion)
• Rules of Court, Rule 45 (petition for review on certiorari)
Factual Background
The Jalaud River’s gradual southward shift dried its original bed adjacent to Lot 861 and encroached on Lot 7328. Degayo’s tenants cultivated the exposed area, believing it to be accretion to Lot 861. Respondents contended it was abandoned riverbed compensating lost land in Lot 7328.
Procedural History
Respondents sued the tenants in Civil Case No. 16047; Degayo’s motion to intervene was denied, and she never challenged that interlocutory order. Separately, Degayo filed Civil Case No. 18328 for declaration of accretion. RTC Branch 27 in No. 16047 ruled for respondents, final in 1999. RTC Branch 22 in No. 18328 ruled for Degayo; respondents appealed to the Court of Appeals.
Court of Appeals Ruling
The CA reversed RTC Branch 22, declaring the disputed area an abandoned riverbed under Article 461. It held that the final judgment in Civil Case No. 16047 was conclusive under the doctrine of res judicata and that Degayo’s accretion claim had been fully litigated therein.
Issues on Review
- Whether the disputed land is accretion to Lot 861 or abandoned riverbed.
- Whether CA properly took judicial notice of Civil Case No. 16047.
- Whether Degayo, not a party in No. 16047, is bound by its judgment under res judicata.
Supreme Court’s Analysis on Res Judicata
Res judicata bars relitigation of issues once judicially determined in a final judgment by a competent court. Under Rule 39 Sec. 47, res judicata encompasses:
• Claim preclusion (bar by prior judgment)
• Issue preclusion (conclusiveness of judgment)
Privity and Identity of Parties and Issues
Although Degayo was not formally impleaded in No. 16047, she testified on the same facts and asserted the same accretion claim through her tenants. The Court applied Torres v. Caluag, holding that a real liti
...continue readingCase Syllabus (G.R. No. L-25176)
Facts of the Case
- The dispute concerns ownership of a parcel of land on the northeastern bank of the Jalaud River in Iloilo, Philippines.
- Lot No. 861 (36,864 sqm), registered under TCT No. T-2804, belonged to the late Marcelo Olmo and Rosalia Labana (Degayo’s parents).
- Opposite Lot No. 861, across the river, lies Lot No. 7328 (153,028 sqm), under TCT No. T-84829, owned jointly by the Magbanua respondents.
- In the 1970’s, the Jalaud River gradually shifted southward, abandoning its old bed (now dry) and encroaching on Lot No. 7328.
- The former riverbed and newly occupied lands amounted to 52,528 sqm: 26,106 sqm of abandoned riverbed and 26,419 sqm encroached from Lot No. 7328.
- Degayo’s tenants cultivated the disputed area in corn and tobacco, treating it as accretion to Lot No. 861.
- The respondents claimed the area was an “abandoned riverbed” and should belong to them proportionally under Article 461 of the Civil Code.
Procedural History
- October 2, 1984: Respondents filed Civil Case No. 16047 (RTC Iloilo, Br. 27) against Degayo’s tenants for ownership and damages over Lot No. 861 and the disputed area.
- Degayo moved to intervene in Civil Case No. 16047; the RTC denied intervention. Degayo did not seek certiorari.
- Degayo instituted Civil Case No. 18328 (RTC Iloilo, Br. 22) against respondents, seeking declaration of ownership and damages over the same disputed land, alleging accretion.
- Degayo testified in Civil Case No. 16047 as defense witness, repeating her inheritance, possession since 1954, and accretion claims.
- May 7, 1996: RTC Branch 27 decided Civil Case No. 16047 in favor of respondents. The tenants’ appeal was dismissed for failure to file a brief; decision became final on August 6, 1999.
- RTC Branch 22 in Civil Case No. 18328 ruled for Degayo, declaring the disputed land accretion to Lot No. 861. Respondents’ motion for reconsideration was denied.
- Respondents appealed Civil Case No. 18328 to the Court of Appeals as CA-G.R. CV No. 62070.
Issue on Accretion and Abandoned Riverbeds
- Whether the disputed parcel is accretion to Lot No. 861 (Degayo’s claim) or an abandoned riverbed redistributed to owners of the land now occupied by the river (respondents’ claim).
- Whether the prin