Case Summary (G.R. No. 214587)
Procedural History
The Peraltas filed a complaint for quieting of title and injunction (January 26, 1998) to prevent the Municipality of Kalibo from converting the accreted parcels into a dumpsite. The RTC (February 22, 2005) declared the parcels as accretion belonging to the Peraltas and enjoined the respondents from occupying 31,320 sq.m. The CA (September 28, 2012) reversed, holding the contested area part of the public domain; its resolution denying reconsideration followed on August 28, 2014. The Supreme Court action for review ensued.
Issue
Whether the CA erred in reversing the RTC’s declaration that the disputed parcels constitute private accretion rather than public land.
Quieting of Title Requirements
To succeed, a plaintiff must establish: (1) legal or equitable title or interest; and (2) invalidity or inoperativeness of the alleged cloud on title despite its prima facie validity. Without registered ownership or proven equitable right, no cause of action for quieting exists.
Ownership and Registration Distinction
Torrens registration confirms and protects title already possessed; it does not vest ownership. Accretions do not automatically form part of a registered lot unless placed under the registration law through specific judicial proceedings. The Peraltas are not registered owners of the accreted parcels, and registration by tax declaration alone does not confer title.
Validity of Quitclaim
The only purported derivation of right is the 1955 quitclaim by Ignacio. No evidence demonstrates Ignacio’s valid title to the accretion; the quitclaim merely extinguished any claim he might have had, without establishing Jose’s lawful acquisition. Equitable title requires that the transferor himself hold a valid right to transfer.
Nature of Accretion under Civil Code Article 457
Article 457 grants accretion to owners of lands adjoining riverbanks only when deposits are (a) gradual and imperceptible; (b) due to water current; and (c) on land adjacent to a riverbank. Ignacio described the parcel as swampy land formed by shoreline recession of the Visayan Sea, not gradual riverine deposit.
DENR Findings and Classification
The DENR’s 1987 inspection by OIC Baltazar Gerardo found predominantly sand, consistent with marine deposition. The DENR and the Department’s ECC classified the land as public domain—either submerged sea area or riverbed. A sheriff’s ocular inspection confirmed tidal reach, supporting public domain status.
Standard of Review on Administrative Findings
Administrative determinations by DENR on public domain classification enjoy respect and are fina
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Facts
- Lot No. 2076 of the Kalibo Cadastre (101,897 sq.m.) was originally covered by OCT No. 24435 in Ana O. Peralta’s name; upon her death, title passed to her brother, Jose Peralta, under TCT No. T-5547 (1975).
- Jose Peralta subdivided Lot 2076 into Lots 2076-A (TCT No. 6166, November 17, 1975) and 2076-B (sold).
- Alleged accretion adjoining Lot 2076 appeared by 1945, recorded as Tax Declaration No. 6466 in Ambrocio Ignacio’s name; Ignacio quitclaimed all interest to Jose for ₱70.44 on March 14, 1955.
- Upon Jose’s death, Lot 2076-A (including supposed accretion) passed to his son Juanito Peralta; TCT No. T-13140 issued September 1, 1983.
- The accretion was separately assessed under Tax Declarations Nos. 21162-A to 21165-A in the names of Juanito, Javier Peralta, Josephine delos Reyes, and Julius Peralta.
- The Municipality of Kalibo sought in 1996–1998 to convert approximately four hectares of the accretion into a garbage dumpsite; erected a retaining wall and perimeter fence along the Aklan River.
- The Peralta siblings, through Juanito as attorney-in-fact, protested to the Municipal Mayor (1992) and to the DENR Secretary (1997) but proceeded with the dumpsite project, relying on an ECC and the view that the land formed part of the public domain.
Procedural History
- January 26, 1998: Petitioners filed a complaint for quieting of title over two portions of the accretion and sought injunctive relief against the dumpsite.
- February 22, 2005: RTC Branch 6, Kalibo, Aklan, ruled in petitioners’ favor, declaring the parcels as accretion (31,320 sq.m.), ordering respondents to desist from occupation; denied damages and attorney’s fees.
- September 28, 2