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REPUBLIC v. ARCADIO IVAN A. SANTOS III

FACTS:

Arcadio Ivan A. Santos III and Arcadio C. Santos, Jr. filed an application for land registration for Lot 4998-B. They initially claimed that the property was formed through accretion and had been in their joint possession for more than 30 years. The City of Parañaque opposed the application, stating that they needed the property for their flood control program and that it was within the legal easement of 20 meters from the river bank. The Regional Trial Court (RTC) granted the application, declaring Arcadio Ivan and Arcadio, Jr. as the true owners of the property. The Republic appealed, and the Court of Appeals affirmed the RTC's ruling. The Supreme Court, however, held that Lot 4998-B was not an accretion and that the application of Article 457 of the Civil Code was erroneous. The Court concluded that the respondents had no legal right to claim ownership of the land.

The ownership of Lot 4998-B was contested by the Republic of the Philippines. The respondents, Arcadio Ivan Santos III and Arcadio Santos Jr., sought the registration of the land under the Torrens system based on the provision of the Civil Code. The Regional Trial Court (RTC) and the Court of Appeals (CA) ruled in favor of the respondents, but the Republic argued that the evidence presented did not establish accretion. The Supreme Court agreed with the Republic and held that the respondents failed to prove that Lot 4998-B was an accretion formed by the current of the river. The Court emphasized that the drying up of the river bed was a significant factor in forming the land. The Court also noted that Transfer Certificate of Title No. 44687 confirmed that Lot 4998-B was formed by the drying up of the Parañaque River.

The State argued that Lot 4998-B is part of the public dominion and owned exclusively by the State. The respondents claimed ownership based on their continuous possession of the property for more than 30 years. The RTC and CA granted their application for land registration, but the State appealed. The State argued that acquisitive prescription does not apply in favor of the respondents since Lot 4998-B is part of the public dominion. The State also challenged the findings of the lower courts regarding the continuous possession of the respondents. The State appealed the decision, arguing that Lot 4998-B is owned exclusively by the State and that the respondents failed to prove their continuous possession.

ISSUES:

  1. Whether the applicants satisfied all the requirements of law for the issuance of a certificate of title.

  2. Whether the applicants have proven that they are entitled to the land in question.

  3. Whether the lower courts erred in their findings.

  4. Whether the respondents acquired ownership over the land through prescription;

  5. Whether the dried-up river bed may be susceptible to acquisitive prescription.

  6. Was the notation on the survey plan sufficient proof of the property's nature as alienable and disposable public land?

  7. Is a surveyor-geodetic engineer's notation on a survey plan a valid act changing the classification of the land?

  8. Whether the land in question has been declared alienable and disposable.

  9. Whether the certifications submitted by the respondent are sufficient evidence to prove that the land is alienable and disposable.

  10. Whether the notation on the survey plan is sufficient to prove that the land is already classified as alienable and disposable.

  11. Whether the respondents can assert acquisitive prescription of the land.

RULING:

  1. The application for the issuance of a certificate of title is granted.

  2. The Republic's claim that the applicants did not satisfy the requirements of law is not proven.

  3. The lower courts erred in their findings.

  4. The respondents did not acquire ownership over the land through prescription, as they failed to prove that the land was already declared as alienable and disposable by the government.

  5. The dried-up river bed is not susceptible to acquisitive prescription, as property of public dominion, such as rivers and their natural beds, are not subject to private appropriation and acquisitive prescription.

  6. The notation on the survey plan was not sufficient proof of the property's nature as alienable and disposable public land. To prove that the land subject of an application for registration is alienable, the applicant must establish the existence of a positive act of the government such as a presidential proclamation, executive order, administrative action, investigation reports of the Bureau of Lands investigator, or a legislative act or statute. In this case, no such proclamation, executive order, administrative action, report, statute, or certification was presented to the Court.

  7. A surveyor-geodetic engineer's notation on a survey plan does not constitute a positive government act validly changing the classification of the land. Only the government has the authority to reclassify lands from public domain to alienable and disposable.

  8. The petitioners have not sufficiently proven that the land in question has been declared alienable. The mere assertion of a surveyor is not enough to reclassify lands of the public domain.

  9. The certifications submitted by the respondent do not prove that the land is alienable and disposable. The government officials who issued the certifications were not presented to testify on their contents. The certifications alone have no probative value in establishing the alienable nature of the land.

  10. The notation on the survey plan does not prove that the land is already classified as alienable and disposable.

  11. The respondents cannot validly assert acquisitive prescription of the land.

PRINCIPLES:

  • Under Section 14(1) of Presidential Decree No. 1529, applicants for confirmation of imperfect title must prove that the land forms part of the alienable and disposable agricultural lands of the public domain and that they have been in open, continuous, exclusive, and notorious possession and occupation of the land under a bona fide claim of ownership since June 12, 1945, or earlier.

  • The findings of fact of the trial court, especially when affirmed by the Court of Appeals, are generally accorded the highest degree of respect and will not be disturbed on appeal, unless certain exceptions are present.

  • Exceptions to the general rule include when the findings are grounded entirely on speculation, surmises, or conjectures; when the inference made is manifestly mistaken, absurd, or impossible; when there is grave abuse of discretion; when the judgment is based on a misapprehension of facts; when the findings of fact are conflicting; when the findings go beyond the issues of the case or are contrary to the admissions of both parties; when the findings are contrary to those of the trial court; when the findings are conclusions without citation of specific evidence; when the facts are undisputed; and when the findings are premised on the absence of evidence and contradicted by the evidence on record.

  • The payment of realty taxes and the conduct of surveys alone are not sufficient evidence to establish continuous, open, public, and adverse possession of a property.

  • Article 419 of the Civil Code distinguishes property as being either of public dominion or of private ownership.

  • Article 420 of the Civil Code lists properties considered as part of public dominion.

  • Article 502 of the Civil Code declares that rivers and their natural beds are of public dominion.

  • Adverse possession which may be the basis of a grant of title in the confirmation of an imperfect title refers only to alienable or disposable portions of the public domain.

  • A dried-up river bed remains property of public dominion unless there has been a natural change in the course of the river.

  • The Regalian doctrine presumes that all lands not otherwise appearing to be clearly within private ownership belong to the State.

  • Occupation of public land in the concept of an owner, no matter how long, cannot ripen into ownership and be registered as a title.

  • To prove that land subject of an application for registration is alienable, the applicant must establish the existence of a positive act of the government such as a presidential proclamation, executive order, administrative action, investigation reports of the Bureau of Lands investigator, or a legislative act or statute.

  • A surveyor-geodetic engineer's notation on a survey plan does not constitute a valid act changing the classification of land from public domain to alienable and disposable. Only the government has the authority to reclassify lands.

  • A mere surveyor has no authority to reclassify lands of the public domain.

  • The applicant for land registration must prove that the DENR Secretary had approved the land classification and released the land of the public domain as alienable and disposable, and that the land subject of the application for registration falls within the approved area per verification through survey by the PENRO or CENRO.

  • The certifications issued by government officials do not, by themselves, prove that the land is alienable and disposable. They are only prima facie evidence of their due execution and date of issuance, but not of the facts stated therein.