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SIAIN ENTERPRISES v. F.F. CRUZ

FACTS:

Western Visayas Industrial Corporation (WESVICO) filed a foreshore lease application in September 1973 but later withdrew it. They then filed a petition for registration of the same foreshore land in March 1976, which was archived due to WESVICO's representative being unreachable. WESVICO's properties, including Lot 3309, were foreclosed by the Development Bank of the Philippines (DBP).

F.F. Cruz & Co. (F.F. Cruz) filed a foreshore lease application in July 1983 over a portion of the foreshore land adjacent to Lot 3309. Senior Special Investigator Ramon Torre recommended that the application be given due course after his investigation. District Land Officer Norberto Bernas also reported that F.F. Cruz was using the land as a sanctuary for marine equipment and had done some filling and introduced facilities on the area.

Siain Enterprises Inc. (SIAIN), the purchaser of the properties previously owned by WESVICO, including Lot 3309, filed a foreshore lease application in September 1986 over the foreshore land adjacent to the properties it bought from DBP. When SIAIN learned that its application overlapped with F.F. Cruz's application, it filed a protest and claimed preference as the owner of the adjoining property. The Sangguniang Panglungsod of Iloilo City approved a resolution giving 70 linear meters to SIAIN and 60 linear meters to F.F. Cruz. The Land Management Bureau (LMB) dismissed SIAIN's protest and ordered that both applications be granted.

SIAIN appealed to the DENR Secretary, arguing that the LMB made false assumptions about the foreshore area, erred in not considering SIAIN's preferential right, and awarded F.F. Cruz 60 linear meters of the disputed area. The DENR Acting Secretary set aside the LMB order and granted SIAIN's application, stating that the contested area was a natural foreshore and SIAIN, as the registered owner of the adjoining land, had the preferential right. F.F. Cruz appealed this decision to the Office of the President.

ISSUES:

  1. Whether the disputed area is reclaimed land or foreshore land

  2. Whether SIAIN has preferential right to lease the disputed area

  3. Whether or not F.F. Cruz has a better right over the filled-up portion of the disputed area.

  4. Whether or not WESVICO, DBP, and SIAIN have waived their preferential right to lease the adjacent foreshore land.

  5. Whether or not the disputed area is a "natural foreshore" subject to the preferential right of the littoral owner.

  6. Whether or not WESVICO waived or abandoned its preferential right to lease the disputed area when it filed an application for registration.

  7. Whether or not the Republic of the Philippines can file a case against private individuals based on an alleged violation of a police regulation.

RULING:

  1. The Court of Appeals ruled that there is no justification to deviate from the findings and conclusions of the Office of the President and the LMB. The disputed area was considered as reclaimed land.

  2. The Court of Appeals dismissed SIAIN's petition and upheld the decision of the Office of the President and the LMB. SIAIN does not have preferential right to lease the disputed area.

  3. F.F. Cruz cannot have a better right over the filled-up portion of the disputed area as the reclamation was made without the necessary permit.

  4. There is no evidence to prove that WESVICO, DBP, and SIAIN have waived their preferential right to lease the adjacent foreshore land as no advice from the Director of Lands was communicated to them regarding their preferential right.

  5. The disputed area is classified as a "natural foreshore" and, as a littoral owner, SIAIN has the preferential right to lease it.

  6. WESVICO did not waive or abandon its preferential right to lease the disputed area when it filed an application for registration, as ownership of the area could not be acquired due to it being part of the public domain.

  7. The Supreme Court ruled in favor of the Republic of the Philippines. The Court held that the Republic, as parens patriae and as the guardian of public interest, has the authority to file a case against private individuals for the violation of a police regulation. The Court emphasized that the objective of such regulation was to preserve and protect the natural resources which are for the benefit of the people. Therefore, the Republic has the right to sue for the enforcement of the regulation, and private individuals can be held liable for their violation.

PRINCIPLES:

  • Priority in time prevails in public land grant. (Priore in tempore, potior jure)

  • Riparian/littoral owners have preference over abutting foreshore lands formed by accretion or alluvial deposits.

  • Foreshore land must be the product of accretion to be subject to riparian or littoral claim.

  • Administrative matters within the executive jurisdiction can only be set aside on proof of gross abuse of discretion, fraud, or error of law.

  • Judicial admission is conclusive and does not require further proof.

  • The littoral owner has a preferential right to lease a foreshore land formed by accretions or alluvial deposits due to the action of the sea.

  • The reason for the preferential right of the littoral owner is to compensate for the diminution of his land caused by the destructive force of the waters.

  • The classification of a disputed area as "reclaimed" does not remove it from its classification as a foreshore area subject to the preferential right of the littoral owner.

  • Filing an application for registration does not waive or abandon the preferential right to lease a disputed foreshore area.

  • The Republic of the Philippines, as parens patriae and as the guardian of public interest, has the authority to file a case against private individuals for the violation of police regulations.

  • Parens patriae refers to the authority of the state to protect those who are unable to protect themselves and to provide for those who are unable to care for themselves.