Case Summary (G.R. No. 200772)
Key Dates and Procedural Milestones
• December 29, 1976 – Original registration application filed (LRC No. 3681-M)
• November 14, 1988 – Notice of initial hearing published
• July 10, 2001 – Regional Trial Court (RTC) Decision favoring Asuncions
• February 26, 2002 – RTC denies Republic’s motion for reconsideration
• September 15, 2006 – Supreme Court grants Republic’s appeal sua sponte
• November 11, 2011 & February 23, 2012 – Court of Appeals (CA) affirms RTC
• February 17, 2021 – Supreme Court issues final ruling under 1987 Constitution
Applicable Law
• 1987 Philippine Constitution: Due process guarantee
• Property Registration Decree (PD No. 1529) and Revised Rules of Court, Rule 132, Section 38 (formal offer of evidence; objections)
• Civil Code Article 457 (alluvial accretion)
• Spanish Law of Waters of 1866, Article 4 (littoral accretion)
• Public Land Act (Sections 58–61 on foreshore lands)
Factual Background
Felipe and Paciencia Asuncion held OCT No. 0-423 (later TCT No. RT-30648) for a 273,819 sqm riparian parcel along the Wawang Dapdap River. In 1976 Paciencia and her children applied for original registration of nine adjoining parcels—later reduced by compromise to five—claiming inheritance, accretion, and thirty-year adverse possession. The Republic opposed as public forest land; competing private claimants (Molina-Enriquez) alleged portions belonged to them.
Trial Court Proceedings
After protracted delays and a 1996 compromise with Molina-Enriquez, the trial court admitted the Asuncions’ evidence (photographs, original tracing cloth plans, surveyor testimony, overseer’s account) and declared the Republic to have waived its presentation when its subpoenaed witness failed to appear. On July 10, 2001, the RTC ordered registration of five parcels in favor of the Asuncions.
Due Process and Evidence Issues
The Republic argued denial of due process: hurried admission of Asuncions’ exhibits, inadequate time to object, refusal to reset hearing after its witness no-show, and denial of its reconsideration motion for alleged pro forma reasons. The SC applied Rule 132, Sec. 38 and jurisprudence on formal offers and objections, finding that although the RTC prematurely admitted exhibits, the Republic itself repeatedly sought and missed extensions, and ultimately failed to timely object or present evidence.
Doctrine on Accretion and Registrability
Under Civil Code Article 457, alluvial accretions—gradual deposits by river currents—vest in riparian owners and are privately acquisitive. Littoral accretions—deposits by sea action—constitute foreshore land, inalienable except by lease (Public Land Act; Waters Law 1866, Art. 4). Riparian owners need only prove accretion; alienability need not be separately established.
Substantive Merits: Accretion Proven
Testimony and maps demonstrated sequential formation of new land southwest of the mother parcel between 1933 and 1948, with shifting river mouth and shoreline. Witnesses described gradual sedimentation by the Wawang Dapdap River, subsequent stabilization, and fishpond development. A 1956 CFI decision between identical parties had earlier adjudicated these lands as accretions upon OCT 0-423, thus establishing res judicata on their nature.
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Facts
- Spouses Felipe and Paciencia Gonzales Asuncion were registered owners of a 273,819 sqm parcel in Bambang, Bulakan, Bulacan (OCT No. 0-423; later TCT No. RT-30648) located along the Wawang Dapdap River.
- On December 29, 1976, Paciencia and her children filed LRC No. 3681-M to register nine parcels (Psu-133934, Psu-138316, Psu-115369 Lots 1 & 2, Psu-115615 Lots 1 & 2, Psu-118984 Lots 1 & 2, Psu-115616 Lot 2), later amended to include Psu-121255, claiming acquisition by inheritance, accretion, and 30-year possession under color of title.
- The Republic (Solicitor General) opposed on the ground that the parcels were unclassified forest land of the public domain; the Molina-Enriquez group also opposed parts of the application.
- After several delays and a compromise with the Molina-Enriquez group (August 30, 1996), the Asuncions withdrew specified lots; the compromise was approved March 22, 1999.
- The Asuncions presented three witnesses:
- Pedro G. Asuncion (possession history, accretion process);
- Roberto M. Valdez (authenticity of tracing cloth plans);
- Carlos G. Martinez (overseer confirming accretion and fishpond improvements since 1944).
- Paciencia died May 19, 1989; her children were substituted as applicants.
- The Republic’s witness failed to appear on June 29, 2001; the trial court declared the State to have closed its evidence.
Procedural History
- July 10, 2001: RTC Branch 21, Malolos, Bulacan ordered registration of parcels Psu-115369, Psu-115615, Psu-115616, Psu-118984, and amended Psu-121255, dividing titles among the Asuncion beneficiaries.
- February 26, 2002: RTC denied the Republic’s motion for reconsideration.
- March 20, 2002: Republic filed notice of appeal; trial court dismissed it as tardy on April 26, 2002.
- CA dismissed petition for certiorari and subsequent motion for reconsideration.
- September 15, 2006: SC granted certiorari, ordered trial cour