Sarmiento vs.

Agana (ART 448)

Facts:
The case of "Sarmiento v. Agana" revolves around a dispute
concerning the ownership and possession of a residential
house built on a parcel of land. The petitioner, Leonila
Sarmiento, filed a Petition for Certiorari challenging a decision
rendered by the Court of First Instance of Pasay City on March
29, 1979. The respondents in the case are District Judge
Enrique A. Agana and the spouses Ernesto Valentino and
Rebecca Lorenzo-Valentino. The events leading to the case
began when Ernesto, while courting his wife Rebecca, was
informed by her mother that they could construct a residential
house on a 145 square meter lot in Parañaque, which they
believed was owned by Rebecca's mother. In 1967, Ernesto
built a house on the land at a cost of P8,000.00 to P10,000.00.
However, it was later discovered that the land was actually
titled in the name of Mr. & Mrs. Jose C. Santos, Jr., who sold it
to Sarmiento on September 7, 1974, for P15,000.00. Sarmiento
subsequently asked Ernesto and his wife to vacate the land on
January 6, 1975, and filed an Ejectment suit against them on
April 21, 1975. The Municipal Court of Parañaque found that
Ernesto and his wife had built the house in good faith and
ordered them to vacate the land after Sarmiento paid them
P20,000.00. The case was elevated to the Court of First
Instance of Pasay, which modified the decision, requiring
Sarmiento to either reimburse Ernesto and his wife P40,000.00
for the house or allow them to purchase the land for
P25,000.00. Sarmiento did not exercise either option, leading
Ernesto to deposit P25,000.00 with the court as the purchase
price for the land. Sarmiento then filed the instant Certiorari
proceedings.
Issue:
1. Whether Ernesto and his wife were builders in good
faith.
2. Whether the Court of First Instance's decision to allow
Ernesto and his wife to purchase the land for
P25,000.00 or to be reimbursed P40,000.00 for the
house was correct.
Ruling:
The Supreme Court dismissed the Petition for Certiorari,
upholding the decision of the Court of First Instance. The court
ruled that Ernesto and his wife were indeed builders in good
faith and that the decision to allow them to either purchase
the land for P25,000.00 or be reimbursed P40,000.00 for the
house was correct.
Ratio:
The Supreme Court agreed that Ernesto and his wife were
builders in good faith due to the peculiar circumstances under
which they constructed the residential house. They believed
the land was owned by Ernesto's mother-in-law, who had given
them permission to build on it. Under Article 448 of the Civil
Code, the owner of the land has the option to either
appropriate the building after paying indemnity or to oblige the
builder to pay the price of the land. The court found that the
valuations of P25,000.00 for the land and P40,000.00 for the
house were supported by evidence. The court cited the case of
Ignacio vs. Hilario, which established that the owner of a
building erected in good faith on another's land is entitled to
retain possession until paid the value of the building. The
landowner cannot refuse both to pay for the building and to
sell the land, compelling the builder to remove the structure.
The court concluded that the decision of the Court of First
Instance was correct and supported by the evidence, and thus,
the Petition for Certiorari was dismissed.

Spouses Macasaet vs. Spouses Macasaet (ART 448)

Facts:
The case involves a dispute between Spouses Ismael and
Teresita Macasaet (petitioners) and Spouses Vicente and
Rosario Macasaet (respondents), who are first-degree
relatives. Ismael is the son of Vicente and Rosario, and Teresita
is his wife. On December 10, 1997, the respondents filed an
ejectment suit against the petitioners in the Municipal Trial
Court in Cities (MTCC) of Lipa City. The respondents claimed
ownership of two parcels of land in Banay-banay, Lipa City,
covered by Transfer Certificate of Title (TCT) Nos. T-78521 and
T-103141. They alleged that the petitioners occupied these lots
under a verbal lease agreement starting in March 1992, with
an agreed rental of P500 per week, which the petitioners failed
to pay despite repeated demands. The petitioners denied the
existence of any lease agreement, asserting that they were
invited by the respondents to construct their residence and
business on the lots to live near each other and help resolve
family problems. They also claimed that one lot was allotted to
Ismael as advance inheritance and the other as payment for
construction materials used in renovating the respondents'
house. The MTCC ruled in favor of the respondents, ordering
the petitioners to vacate the premises, finding that their
occupation was by mere tolerance of the respondents. The
Regional Trial Court (RTC) upheld the MTCC's decision but
allowed the respondents to appropriate the improvements
made by the petitioners after paying indemnity. The Court of
Appeals (CA) affirmed the lower courts' decisions with
modifications, including reimbursement for half the value of
the improvements. The petitioners then brought the case to
the Supreme Court.
Issue:
1. Whether the Complaint should have been dismissed
due to the alleged failure to prove a verbal lease
agreement.
2. Whether the rule on appearance of parties during the
Preliminary Conference in an unlawful detainer suit
was properly applied.
3. Whether Article 1678 or Article 448 of the Civil Code
should apply regarding the improvements made by
the petitioners.
4. Whether the Decision of the Court of Appeals is
supported by evidence, appropriate laws, rules, and
jurisprudence.
5. Whether the MTCC judge and respondents' lawyers
should be held accountable for their actions in the
case.
Ruling:
 1. The Supreme Court ruled that the petitioners failed to
justify their right to retain possession of the lots, and
the respondents, as owners, are entitled to physical
possession.
2. The Court found that the appearance of a
representative with written authorization from the
respondents during the preliminary conference was
valid.
3. The Court held that Article 448 of the Civil Code,
rather than Article 1678, should apply to the
improvements made by the petitioners.
4. The Court affirmed the CA's decision with
modifications, deleting the reimbursement of
P475,000 and remanding the case to the court of
origin for further proceedings to determine the
appropriate indemnity under Articles 448 and 546 of
the Civil Code.
5. The Court found no need to address the
accountability of the MTCC judge and respondents'
lawyers.
Ratio:
The Supreme Court's decision was based on several legal
principles and factual findings. The Court emphasized that in
ejectment proceedings, the main issue is the right to physical
possession. The petitioners' occupation of the lots was initially
lawful but became unlawful upon the respondents' demand to
vacate. The Court found that the petitioners' possession was
not merely tolerated but was based on an implied agreement
arising from familial love and solidarity. However, this
agreement terminated when the relationship between the
parties deteriorated. The Court also clarified that the rules on
pretrial could supplement the rules on preliminary conference,
allowing a representative with special authorization to appear.
Regarding the improvements, the Court applied Article 448 of
the Civil Code, which governs the rights of a builder in good
faith. The Court found that the petitioners built the
improvements with the respondents' consent, thus acting in
good faith. The case was remanded to the lower court to
determine the appropriate indemnity for the improvements,
considering the options provided under Article 448. The
Court's decision was guided by the principles of equity and
substantial justice, aiming to resolve the dispute fairly and
promptly.

Department of Education vs. Casibang (ART 448)

Facts:
The case involves a legal dispute between the Department of
Education (DepEd), represented by its Regional Director, and
the respondents Delfina C. Casibang, Angelina C. Canapi,
Erlinda C. Bajan, Lorna G. Gumabay, Dionisia C. Alonzo, Maria
C. Bangayan, and Digna C. Binayug. The property in question is
a 7,532 square meter portion of Lot 115, covered by Original
Certificate of Title (OCT) No. O-627, registered under the name
of Juan Cepeda, the respondents' late father. In 1965, upon the
request of then Mayor Justo Cesar Caronan, Cepeda allowed
the construction and operation of a school on the western
portion of his property, now known as Solana North Central
School, under the control of DepEd. Despite Cepeda's death in
1983, his descendants continued to tolerate the school's use of
the property. However, between October 31, 2000, and
November 2, 2000, the respondents occupied a portion of the
property, leading to a demand from the school officials for
them to vacate, which they refused, asserting ownership of the
lot.
DepEd filed a Complaint for Forcible Entry and Damages
against the respondents before the Municipal Circuit Trial
Court (MCTC) of Solana-Enrile, which ruled in favor of DepEd.
The Regional Trial Court (RTC) affirmed this decision.
Subsequently, the respondents demanded that DepEd either
pay rent, purchase the area, or vacate the premises. DepEd
refused, leading the respondents to file an action for Recovery
of Possession and/or Sum of Money on March 16, 2004. The
RTC ruled in favor of the respondents, declaring them the
owners of the property and ordering DepEd to pay the value of
the property. The Court of Appeals (CA) affirmed this decision.
DepEd, through the Office of the Solicitor General (OSG),
appealed to the Supreme Court, arguing that the respondents'
right to recover the property was barred by prescription and/or
laches.
Issue:
1. Is the respondents' right to recover the possession of
the subject property barred by prescription and/or
laches?
Ruling:
The Supreme Court denied the petition of DepEd and affirmed
the decision of the Court of Appeals, which upheld the RTC's
ruling that the respondents are the owners of the property.
The case was remanded to the trial court to determine the
value of the subject property. If the value of the property is less
than the value of the buildings and improvements, DepEd is
ordered to pay such amount. If the value of the property is
greater than the value of the buildings and improvements,
DepEd is ordered to pay reasonable rent in accordance with
the agreement of the parties. In case of disagreement, the trial
court shall fix the amount of reasonable rent.
Ratio:
The Supreme Court found that the respondents' right to
recover the property was not barred by laches. Laches is the
failure or neglect to assert a right within a reasonable time,
leading to a presumption that the party has abandoned it.
However, laches is an equitable doctrine and cannot be used
to defeat justice or perpetrate fraud. The Court noted that the
possession of the property by DepEd was by mere tolerance of
the respondents and their predecessor, Juan Cepeda. The
respondents presented sufficient evidence, including the OCT
No. O-627, tax declarations, and tax receipts, to prove their
ownership. DepEd failed to present any evidence to
substantiate its claim of ownership through purchase by civic-
minded residents.
The Court emphasized that a certificate of title under the
Torrens system serves as evidence of an indefeasible and
incontrovertible title to the property. The respondents, as
registered owners, have the right to eject any person illegally
occupying their property, and this right is imprescriptible. The
Court also ruled that DepEd, as a builder in good faith, is
subject to the provisions of Article 448 and Article 546 of the
Civil Code, which provide for the rights of landowners and
builders in good faith. The trial court's decision to order DepEd
to pay the value of the property or reasonable rent was
deemed appropriate, considering the impracticality of
restoring possession to the respondents.

Spouses Del Campo vs. Abesia (ART 448)

Facts:
The case of Spouses Concepcion Fernandez Del Campo and
Estanislao Del Campo (plaintiffs-appellees) versus Bernarda
Fernandez Abesia (defendant-appellant) revolves around a
parcel of land, Lot No. 1161 of the Cadastral Survey of Cebu,
with an area of approximately 45 square meters. This land is
situated at the corner of F. Flores and Cavan Streets, Cebu City,
and is covered by Transfer Certificate of Title (TCT) No. 61850.
The plaintiffs and the defendant were co-owners of this lot,
with the plaintiffs holding a 2/3 share and the defendant a 1/3
share. The plaintiffs filed an action for partition in the Court of
First Instance (CFI) of Cebu. The trial court appointed a
commissioner who conducted a survey, prepared a sketch plan,
and submitted a report recommending the division of the
property into two lots: Lot 1161-A (30 square meters) for the
plaintiffs and Lot 1161-B (15 square meters) for the defendant.
The survey revealed that the defendant's house encroached
upon 5 square meters of Lot 1161-A. The trial court ruled that
the plaintiffs could not be obliged to pay for the value of the
encroaching portion of the defendant's house, nor could the
defendant be obliged to pay for the price of the 5 square
meters. Consequently, the court ordered the defendant to
remove and demolish the encroaching part of her house at her
own expense. The defendant appealed this decision.
Issue:
1. Did the trial court err in not applying the rights of a
builder in good faith under Article 448 of the Civil
Code to the defendant with respect to the portion of
her house occupying the lot assigned to the plaintiffs?
2. Did the trial court err in ordering the defendant to
remove and demolish the encroaching part of her
house at her own expense?
Ruling:
The Supreme Court modified the decision of the trial court. It
ruled that the plaintiffs have the right to appropriate the
encroaching portion of the defendant's house upon payment
of indemnity to the defendant as provided for in Article 546 of
the Civil Code. Alternatively, the defendant may be obliged to
pay the price of the land occupied by her house. If the price of
the land is considerably more than the value of the
encroaching portion of the house, the defendant cannot be
obliged to buy the land but must pay reasonable rent. In case
of disagreement, the trial court shall fix the terms. The
defendant may also choose to remove or demolish the
encroaching portion of her house at her own expense.
Ratio:
The Supreme Court held that Article 448 of the Civil Code,
which grants rights to a builder in good faith, applies even in
cases where co-ownership has been terminated by partition.
The court noted that while Article 448 generally does not apply
to co-owners building on common property, it becomes
applicable once the co-ownership is terminated and good faith
is established. The court cited legal scholars Manresa and
Navarro Amandi, who agree that Article 448 can apply in such
situations. The court emphasized that the plaintiffs have the
right to appropriate the encroaching portion of the house upon
payment of indemnity or to oblige the defendant to pay for the
land. If the land's price is significantly higher than the value of
the house portion, the defendant must pay reasonable rent.
The court's decision ensures that the rights of both parties are
balanced and that the defendant, as a builder in good faith, is
not unduly penalized.

Pleasantville Development Corp. vs. Court of Appeals (Builder

Facts:
This case involves Pleasantville Development Corporation
(petitioner) and respondents Court of Appeals, Wilson Kee, C.T.
Torres Enterprises, Inc. (CTTEI), and Eldred Jardinico. The
conflict began when Edith Robillo purchased Lot 9 in
Pleasantville Subdivision, Bacolod City, from the petitioner. In
1975, Robillo sold her rights to Eldred Jardinico. Jardinico later
discovered that Lot 9 had been mistakenly occupied by Wilson
Kee. Kee had bought Lot 8 on installment from CTTEI, the
exclusive real estate agent of the petitioner, but was
erroneously shown Lot 9 by CTTEI's employee, Zenaida
Octaviano. Kee subsequently built several improvements on
Lot 9. When Jardinico demanded that Kee vacate Lot 9, Kee
refused, prompting Jardinico to file an ejectment case. Kee
then filed a third-party complaint against the petitioner and
CTTEI. The Municipal Trial Court in Cities (MTCC) ruled in favor
of Jardinico, ordering Kee to vacate Lot 9 and pay rentals, while
holding CTTEI and the petitioner liable for attorney's fees. On
appeal, the Regional Trial Court (RTC) initially ruled that the
petitioner and CTTEI were not at fault. However, the Court of
Appeals reversed this decision, declaring Kee a builder in good
faith and holding CTTEI and the petitioner liable.
Issue:
1. Was Kee a builder in good faith?
2. What is the liability, if any, of the petitioner and its
agent, CTTEI?
3. Is the award of attorney's fees proper?
Ruling:
The Supreme Court partially granted the petition, modifying
the decision of the Court of Appeals. The Court declared Kee a
builder in good faith and held the petitioner and CTTEI
solidarily liable for damages due to negligence. However, since
the amount and/or extent of such damages was not proven
during the trial, they could not be quantified and awarded. The
Court also ordered the petitioner and CTTEI to pay P3,000.00
to Jardinico as attorney's fees and litigation expenses, and
dispensed with the award of rentals to Jardinico.
Ratio:
The Court upheld the Court of Appeals' finding that Kee was a
builder in good faith, as he believed Lot 9 to be the lot he had
purchased and was unaware of any defect in his title. The Court
emphasized that good faith is presumed, and the burden of
proving bad faith lies with the petitioner, which it failed to do.
The negligence of CTTEI, the petitioner's agent, in pointing out
the wrong lot to Kee was established, making the petitioner
liable under Articles 1909 and 1910 of the Civil Code. The Court
also found that the award of attorney's fees was within the
discretion of the Court of Appeals, given that Jardinico was
compelled to litigate to protect his interests due to the
negligence of the petitioner's agent. The Court noted that the
deed of sale between Kee and Jardinico, executed during the
pendency of the appeal, settled their rights and obligations
regarding Lot 9, rendering the remand for further proceedings
unnecessary.

Rosales vs. Castelltort (ART 448)

Facts:
In the case of "Rosales v. Castelltort," the petitioners, Rodolfo
V. Rosales and Lily Rosqueta-Rosales, were the registered
owners of a 315-square-meter parcel of land in Los Baños,
Laguna, covered by Transfer Certificate of Title (TCT) No.
36856. On August 16, 1995, they discovered that a house was
being constructed on their lot without their knowledge or
consent by respondent Miguel Castelltort. The Castelltorts had
purchased Lot 16 in the same subdivision from respondent Lina
Lopez-Villegas, through her attorney-in-fact Rene Villegas.
However, due to a survey error by geodetic engineer Augusto
Rivera, Lot 17 was mistakenly identified as Lot 16. Negotiations
for settlement failed, leading the Rosaleses to file a complaint
for recovery of possession and damages on September 1, 1995,
in the Regional Trial Court (RTC) of Calamba, Laguna. The RTC
ruled in favor of the Rosaleses, finding the Castelltorts and
Villegas negligent and in bad faith, and ordered the surrender
of the property and payment of damages. The Castelltorts
appealed to the Court of Appeals (CA), which reversed the
RTC's decision, recognizing the good faith of the Castelltorts
and applying Article 448 of the Civil Code. The CA remanded
the case to the RTC for further proceedings to determine the
fair price of the land and the expenses for the house. The
Rosaleses then filed a petition for review on certiorari with the
Supreme Court.
Issue:
1. Whether the Court of Appeals committed a grave
abuse of discretion in making a finding contrary to the
admissions by the parties.
2. Whether the Court of Appeals committed a reversible
error of law in concluding that the trial court relied on
flimsy, if not immaterial, allegations in determining
the good faith of the respondents.
 3. Whether the Court of Appeals committed a reversible
error of law in rendering a decision unenforceable
against respondent Judith Castelltort and third-party
Elizabeth Cruz.
Ruling:
The Supreme Court denied the petition and affirmed the CA's
decision with modification. The trial court was directed to
determine the increase in value ("plus value") of the Rosaleses'
lot due to the house built before the Castelltorts were notified
of the rightful claim and the current fair market value of that
portion.
Ratio:
The Supreme Court held that the CA correctly found the
Castelltorts to be builders in good faith, as they relied on the
title and the survey conducted by Villegas. The Court
emphasized that good faith is presumed under Article 527 of
the Civil Code, and the burden of proving bad faith rests on the
party alleging it. The Court also noted that the confusion in
identifying Lot 16 was due to an error by the geodetic engineer,
not the Castelltorts. The Court applied Article 448 of the Civil
Code, which allows the landowner to choose between
appropriating the building by paying indemnity or obliging the
builder to pay for the land. The Court modified the CA's
decision to include the determination of the "plus value" of the
land due to the house built in good faith. The Court also
clarified that the payment of reasonable rent should
commence from the time the Castelltorts' good faith ceased,
which was when they were notified of the Rosaleses' claim on
August 21, 1995.

Spouses Firme vs. Bukal Enterprises and Development Corp.

Facts:
The case involves Spouses Constante and Azucena Firme
("Spouses Firme"), the registered owners of a parcel of land
located on Dahlia Avenue, Fairview Park, Quezon City. Bukal
Enterprises and Development Corporation ("Bukal
Enterprises"), represented by its vice president Renato de
Castro, authorized broker Teodoro Aviles to negotiate the
purchase of the property. On 28 March 1995, Bukal Enterprises
filed a complaint for specific performance and damages,
alleging that the Spouses Firme reneged on their agreement to
sell the property. The trial court ruled in favor of the Spouses
Firme, holding that there was no perfected contract of sale due
to the lack of consent from the sellers. Bukal Enterprises
appealed, and the Court of Appeals reversed the trial court's
decision, finding that there was a perfected contract of sale
and ordering the Spouses Firme to execute the deed of sale.
The Spouses Firme then petitioned the Supreme Court for
review.
Issue:
1. Was there a perfected contract of sale between the
Spouses Firme and Bukal Enterprises?
 2. Is the alleged contract of sale enforceable despite
being covered by the Statute of Frauds?
3. Was it legally and factually possible for Bukal
Enterprises to perfect a contract of sale?
4. Was the award of moral and compensatory damages
to the Spouses Firme proper?
Ruling:
The Supreme Court ruled in favor of the Spouses Firme, setting
aside the decision of the Court of Appeals. The Court declared
that there was no perfected contract of sale and ordered Bukal
Enterprises to pay the Spouses Firme P30,000 as nominal
damages.
Ratio:
The Supreme Court found that there was no consent from the
Spouses Firme to sell the property, which is an essential
element for a valid contract. The testimonies of Aviles and De
Castro were inconsistent and did not establish a meeting of the
minds between the parties. The Spouses Firme consistently
rejected the terms presented by Aviles and informed him that
they were not interested in selling the property. Additionally,
Aviles did not have the proper authority from Bukal
Enterprises' Board of Directors to negotiate and finalize the
purchase. The Court also noted that the application of the
Statute of Frauds presupposes the existence of a perfected
contract, which was not present in this case. Furthermore,
Bukal Enterprises was deemed a builder in bad faith for
introducing improvements on the property despite knowing
that the Spouses Firme were not selling. The award of
compensatory and moral damages was deleted, but nominal
damages were awarded to recognize the violation of the
Spouses Firme's property rights.

Heirs of Narvasa, Sr. vs. Imbornal

Facts:
The case involves a dispute over a parcel of land and its
accretions situated in Sabangan, Barangay Nibaliw West, San
Fabian, Pangasinan. The petitioners, Heirs of Francisco I.
Narvasa, Sr., and Heirs of Petra Imbornal and Pedro Ferrer,
represented by their Attorney-in-Fact, Mrs. Remedios B.
Narvasa-Regacho, filed a complaint for reconveyance,
partition, and/or damages against the respondents, Emiliana,
Victoriano, Felipe, Mateo, Raymundo, Maria, and Eduardo, all
surnamed Imbornal. The land in question was originally owned
by Basilia Imbornal and was conveyed to her three daughters,
Balbina, Alejandra, and Catalina, in 1920. Catalina's husband,
Ciriaco Abrio, applied for and was granted a homestead patent
over a 31,367-sq.m. riparian land (Motherland) adjacent to the
Cayanga River. The Motherland was covered by Original
Certificate of Title (OCT) No. 1462 issued in Ciriaco's name on
December 5, 1933. The First Accretion, approximately 59,772
sq.m., adjoined the southern portion of the Motherland and
was covered by OCT No. P-318 issued in the name of
respondent Victoriano on August 15, 1952. The Second
Accretion, with an area of 32,307 sq.m., abutted the First
Accretion and was covered by OCT No. 21481 issued in the
names of all the respondents on November 10, 1978.
The petitioners claimed that Ciriaco, with the help of his wife
Catalina, urged Balbina and Alejandra to sell the Sabangan
property to fund his homestead patent application over the
Motherland. In return, Ciriaco allegedly agreed to hold the
Motherland in trust for the Imbornal sisters. The petitioners
also alleged that the respondents fraudulently registered the
accretions in their names. The Regional Trial Court (RTC) of
Dagupan City, Branch 44, ruled in favor of the petitioners,
directing the respondents to reconvey the properties or their
pecuniary equivalent and to pay damages. However, the Court
of Appeals (CA) reversed the RTC's decision, declaring the
descendants of Ciriaco as the exclusive owners of the
Motherland, the descendants of respondent Victoriano as the
exclusive owners of the First Accretion, and the descendants of
Pablo Imbornal as the exclusive owners of the Second
Accretion. The petitioners then filed a petition for review on
certiorari before the Supreme Court.
Issue:
1. Whether the descendants of Ciriaco are the exclusive
owners of the Motherland.
2. Whether the descendants of respondent Victoriano
are the exclusive owners of the First Accretion.
3. Whether the descendants of Pablo (respondents
collectively) are the exclusive owners of the Second
Accretion.
4. Whether the action for reconveyance is barred by
prescription.
5. Whether an implied trust exists between the
Imbornal sisters and Ciriaco.
Ruling:
The Supreme Court denied the petition and affirmed the CA's
decision, thereby dismissing the Amended Complaint filed by
the petitioners.
Ratio:
The Supreme Court found that the causes of action pertaining
to the Motherland and the First Accretion were barred by
prescription. An action for reconveyance based on an implied
trust prescribes in ten years from the date of registration of the
deed or the issuance of the certificate of title if the plaintiff is
not in possession. The Amended Complaint was filed on
February 27, 1984, beyond the ten-year prescriptive period for
the Motherland (OCT No. 1462 issued on December 5, 1933)
and the First Accretion (OCT No. P-318 issued on August 15,
1952). Therefore, the complaint with respect to these
properties should have been dismissed based on prescription.
Regarding the existence of an implied trust, the Court held that
the petitioners failed to provide clear and convincing evidence
to prove that Ciriaco held the Motherland in trust for the
Imbornal sisters. The homestead patent awarded to Ciriaco
required stringent conditions, which he presumably satisfied.
The oral evidence presented by the petitioners was not
sufficient to establish the alleged trust, especially given the lack
of documentary evidence and the passage of time since the
purported agreement in the 1920s.
As for the accretions, the Court noted that the petitioners were
not the riparian owners of the Motherland to which the First
Accretion had attached. Consequently, they could not assert
ownership over the First Accretion or the Second Accretion,
which had attached to the First Accretion. The respondents, on
the other hand, had acquired title to the accretions through
prescription and had registered them under the Torrens
system, making their titles indefeasible. Therefore, the
petitioners' action for reconveyance with respect to the
accretions also failed.

Ronquillo vs. Court of Appeals (ACCRETION/ALLUVIUM)

Facts:
The case of "Ronquillo v. Court of Appeals" revolves around a
dispute concerning the ownership of a dried-up portion of
Estero Calubcub in Sampaloc, Manila. The petitioner, Mario C.
Ronquillo, and the respondents, Rosendo del Rosario, Amparo
del Rosario, and Florencia del Rosario, are the primary parties
involved. The Del Rosarios claimed ownership of the dried-up
portion as riparian owners, asserting that it was part of their
property, Lot 34, Block 9, Sulucan Subdivision, covered by
Transfer Certificate of Title No. 34797. Ronquillo, who had
occupied the disputed land since 1945, contended that the
land was public domain and not subject to private ownership.
The trial court ruled in favor of the Del Rosarios, declaring them
the rightful owners of the dried-up portion. This decision was
affirmed by the Court of Appeals, which held that the dried-up
portion belonged to the Del Rosarios due to a natural change
in the course of the estero. Ronquillo then filed a petition for
certiorari with the Supreme Court, challenging the appellate
court's decision.
Issue:
1. Did the dried-up portion of Estero Calubcub result
from a natural change in the course of the waters?
2. Is Article 370 of the old Civil Code applicable to this
case, thereby entitling the Del Rosarios to ownership
of the dried-up portion as riparian owners?
Ruling:
The Supreme Court reversed and set aside the decision of the
Court of Appeals, ruling that the dried-up portion of Estero
Calubcub is public land and not subject to private ownership.
Consequently, the Del Rosarios cannot claim ownership of the
dried-up portion as riparian owners.
Ratio:
The Supreme Court determined that the change in the course
of Estero Calubcub was not due to natural forces but was
caused by human activity, specifically the dumping of garbage
by local residents. This conclusion was supported by the
testimony of Florencia del Rosario and the relocation plan
presented in court. Since the change was man-made, Article
370 of the old Civil Code, which applies only to natural changes
in the course of waters, was deemed inapplicable. The Court
emphasized that the rules on alluvion do not apply to man-
made or artificial accretions. Furthermore, the dried-up
portion of Estero Calubcub was considered part of the public
domain, which cannot be acquired through private ownership.
The Court also noted that both parties had filed sales
applications with the Bureau of Lands, implicitly
acknowledging that the land was public. Therefore, they were
estopped from claiming otherwise. The decision was based on
the 1987 Philippine Constitution, as the case decision date was
1991.

Republic vs. Santos III (ACCRETION)

Facts:
The case involves the Republic of the Philippines as the
petitioner and Arcadio Ivan A. Santos III and Arcadio C. Santos,
Jr. as the respondents. On March 7, 1997, Arcadio Ivan applied
for the registration of Lot 4998-B, located in Barangay San
Dionisio, Parañaque City, claiming continuous and adverse
possession of the property for over ten years. The property,
measuring approximately 1,045 square meters, was bounded
by Lot 4079 (owned by Arcadio Jr.) in the Northeast, the
Parañaque River in the Southeast, an abandoned road in the
Southwest, and Lot 4998-A (also owned by Arcadio Ivan) in the
Northwest. On May 21, 1998, the application was amended to
include Arcadio Jr. as a co-applicant, alleging joint possession
for more than 30 years and that the property was formed
through accretion. The City of Parañaque opposed the
application, arguing that the property was needed for flood
control, was within the legal easement of 20 meters from the
river bank, and was an orchard that had dried up rather than
formed through accretion. On May 10, 2000, the RTC granted
the application, declaring the respondents as the true and
absolute owners of Lot 4998-B. The Republic, through the
Office of the Solicitor General (OSG), appealed this decision.
Issue:
1. Did the property sought to be registered qualify as an
accretion to the respondents' adjoining land under
Article 457 of the Civil Code?
2. Could the respondents claim the property by virtue of
acquisitive prescription under Section 14 (1) of
Presidential Decree No. 1529?
3. Was the failure to formally offer evidence that the
subject property is alienable and disposable fatal to
the respondents' application for land registration?
4. Did the respondents sufficiently establish their
continuous, open, public, and adverse occupation of
the subject property for more than thirty years?
Ruling:
1. No, the property did not qualify as an accretion under
Article 457 of the Civil Code.
2. No, the respondents could not claim the property by
virtue of acquisitive prescription as the property was
not proven to be alienable and disposable public land.
3. Yes, the failure to formally offer evidence that the
property is alienable and disposable was fatal to the
respondents' application.
4. No, the respondents did not sufficiently establish
their continuous, open, public, and adverse
 occupation of the subject property for more than
thirty years.
Ratio:
The Supreme Court found that the lower courts erred in
applying Article 457 of the Civil Code, which pertains to
accretion. The evidence presented by the respondents
indicated that Lot 4998-B was a dried-up river bed, not formed
through the gradual and imperceptible deposit of soil by the
current of the river. Therefore, the property did not qualify as
an accretion. The Court emphasized that the dried-up river bed
remains property of public dominion and belongs to the State,
as per Article 502 of the Civil Code. Furthermore, the
respondents failed to provide competent proof that the
property was declared alienable and disposable by the
Government, which is a prerequisite for claiming ownership
through acquisitive prescription. The Court also noted that the
payment of realty taxes and conducting surveys did not
conclusively prove continuous, open, public, and adverse
possession. The Supreme Court reversed the decision of the
Court of Appeals and dismissed the respondents' application
for land registration, declaring Lot 4998-B as exclusively
belonging to the State.

Daclison vs. Baytion (ART 445/457/ACCRETION)

Facts:
The case of "Daclison v. Baytion" revolves around a land
dispute in Quezon City. On January 27, 2009, Eduardo Baytion
(respondent) filed a complaint for Forcible Entry and Damages
with a Prayer for Issuance of Preliminary Mandatory Injunction
against Rex Daclison (petitioner) in the Metropolitan Trial
Court (MeTC), Branch 43, Quezon City, docketed as Civil Case
No. 39225. Baytion claimed co-ownership of a 1,500 square
meter parcel of land covered by Transfer Certificate Title (TCT)
No. 221507, which he inherited from his parents and
administered. He leased portions of this property to third
parties, including a one-storey building divided into seven units
or stalls. One stall was leased to Leonida Dela Cruz for her
business of selling construction materials. After Leonida's lease
expired in May 2008, Daclison and others took possession of
the stall without Baytion's consent and used it for their
business without paying rent. Despite demands to vacate,
Daclison refused, prompting Baytion to file the complaint.
Daclison countered that the property in question was leased to
Antonio dela Cruz in 1978, who later filled up a down-sloping
area beside the property. Antonio's business was taken over by
Leonida and then by Ernanie Dela Cruz, with whom Daclison
entered into a business venture in February 2008. Daclison
claimed that Baytion agreed to let them transfer to the filled-
up portion of the property, but later demanded they vacate it.
The MeTC dismissed the case for not including Baytion's co-
owners as plaintiffs, but the Regional Trial Court (RTC) assumed
jurisdiction and ruled in favor of Baytion, ordering Daclison to
vacate and pay monthly rent. The Court of Appeals (CA)
affirmed the RTC's decision, leading to Daclison's petition for
review by the Supreme Court.
Issue:
1. Did the RTC err in exercising original jurisdiction over
the case and deciding it on its merits?
2. Who has the better right to possess the disputed
portion of the property?
3. Is the disputed portion an accretion or an
improvement on the property covered by TCT No.
221507?
4. Does Baytion have the legal capacity to sue?
5. Should Daclison pay P20,000 monthly for the use of
the premises?
Ruling:
The Supreme Court granted the petition, reversing and setting
aside the February 5, 2015 Decision and the August 3, 2015
Resolution of the Court of Appeals. The complaint for
possession filed by Baytion was dismissed.
Ratio:
The Supreme Court found that the disputed portion was the
filled-up area between the riprap constructed by the
government and the property covered by TCT No. 221507. The
Court held that this portion could not be considered an
accretion under Article 457 of the New Civil Code because the
deposit was not gradual and imperceptible, nor was it the
exclusive result of the current from the creek. The deposits
were artificial and man-made. Additionally, the disputed
property could not be considered an improvement or
accession under Article 445 of the Civil Code, as the supposed
improvement must be made within or on the property, not
outside it. Therefore, Baytion did not have a better right to
possess the contested portion, and his claim of ownership was
without basis. Consequently, he had no cause of action to eject
Daclison.

Spouses Baes vs. Court of Appeals (ART 461)

Facts:
The case involves Spouses Felix Baes and Rafaela Baes
(petitioners) against the Court of Appeals and the Republic of
the Philippines (respondents). The controversy began in 1962
when the government dug a canal on a private parcel of land,
identified as Lot 2958, to streamline the Tripa de Gallina creek.
This lot, covering an area of 33,902 sq.m., was later acquired
by Felix Baes, who registered it under TCT No. 10990 and
subdivided it into three lots: Lot 2958-A (28,889 sq.m.), Lot
2958-B (3,588 sq.m.), and Lot 2958-C (452 sq.m.), covered by
TCT Nos. 11041, 11042, and 11043, respectively. In exchange
for Lot 2958-B, which was totally occupied by the canal, the
government gave Baes a lot with the same area, Lot 3271-A,
through a Deed of Exchange of Real Property dated June 20,
1970. This new lot was registered under TCT No. 24300. Baes
later resurveyed and subdivided Lot 2958-C and a portion of
Lot 2958-A, resulting in new TCTs. In 1978, the Republic
discovered that Lot 1-B (TCT No. 14405) covered a filled-up
portion of the Tripa de Gallina creek and that Lot 2958-C had
been unlawfully enlarged. The Republic filed a petition for
cancellation of the TCTs on November 17, 1982. The trial court
ruled in favor of the Republic, declaring the TCTs null and void
and ordering their cancellation. The Court of Appeals affirmed
this decision, leading to the present appeal by certiorari.
Issue:
1. Are the petitioners entitled to ownership of the dried-
up portion of the Tripa de Gallina creek under Article
461 of the Civil Code?
2. Have the petitioners already been fully compensated
for the loss of their land due to the government's
diversion of the river?
Ruling:
1. The petitioners are not entitled to ownership of the
dried-up portion of the Tripa de Gallina creek.
2. The petitioners have already been fully compensated
for the loss of their land.
Ratio:
The Supreme Court ruled that the petitioners are not entitled
to ownership of the dried-up portion of the Tripa de Gallina
creek under Article 461 of the Civil Code. Article 461 states that
river beds abandoned through the natural change in the course
of the waters belong to the owners whose lands are occupied
by the new course. However, the court noted that the change
in the course of the river was due to artificial means,
specifically the government's construction of a canal. The court
agreed with the Solicitor General's argument that allowing the
petitioners to acquire ownership of the dried-up portion of the
creek would result in double compensation and unjust
enrichment at the expense of the state. The court found that
the petitioners had already been fully compensated through
the Deed of Exchange of Real Property dated June 20, 1970,
where Felix Baes received Lot 3271-A in exchange for Lot 2958-
B. This exchange was deemed fair as the lots were of the same
area and value, and the agreement was voluntarily entered
into by both parties. The court also noted that if the
negotiations had failed, the government could have taken Lot
2958-B under the power of eminent domain, upon payment of
just compensation, as the land was needed for a public
purpose. Therefore, the petition was denied, with costs against
the petitioners.

Celestial vs. Cachopero

Facts:
In the case of "Celestial v. Cachopero," the dispute centers on
a 415 square meter parcel of land located in Barrio 8,
Midsayap, Cotabato, previously part of the Salunayan Creek.
The petitioner, Rachel C. Celestial, and the respondent, Jesse
Cachopero, are siblings. Jesse filed a Miscellaneous Sales
Application (MSA) with the Bureau of Lands, claiming he had
been occupying the land since 1968 and had built a residential
house on it. Rachel protested, asserting a preferential right
over the land as it was adjacent to her residential house and
served as her only outlet to the national highway.
An ocular inspection by the Bureau of Lands found the land to
be outside the commerce of man and not susceptible to private
acquisition. Consequently, Jesse's MSA was denied, and he was
allowed only temporary occupancy. Rachel then filed an
ejectment case against Jesse and his wife, resulting in a
compromise agreement where Jesse agreed to vacate the
premises.
Subsequently, Jesse filed another MSA for a portion of the
same land. This time, his application was supported by
certifications from the Office of the Mayor and the District
Engineer stating that the land was suitable for residential
purposes and no longer needed by the municipal government.
Rachel protested again, asserting her preferential right and
demanding a five-meter road right of way.
The DENR Regional Executive Director ordered that the land be
sold at public auction due to the conflicting interests of the
parties, dismissing Jesse's second MSA. Jesse filed a petition
for certiorari, prohibition, and mandamus with the RTC of
Midsayap, which was dismissed for lack of merit and non-
exhaustion of administrative remedies. The Court of Appeals
reversed the RTC's decision, ordering the DENR to process
Jesse's MSA. Rachel then filed the present petition before the
Supreme Court.

Issue:
1. Was the land in question public land, and should it be
subject to sale at public auction under Section 67 of
the Public Land Act or private sale under R.A. 730?
Ruling:
1. The Supreme Court ordered the DENR to process
Jesse's MSA pursuant to R.A. 730.
Ratio:
The Court further noted that the land in question, being a
dried-up river bed, was initially part of the public domain and
not susceptible to private acquisition. However, with
certifications from the local government that the land was
suitable for residential purposes and no longer needed for
public improvements, it became alienable and disposable. The
DENR was thus mandated to process Jesse's MSA and
determine his qualification to purchase the land under R.A.
730.
Finally, the Court addressed Rachel's claim of ownership based
on adverse possession and the right of accession, stating that
property of public dominion is not susceptible to private
appropriation and acquisitive prescription. The Court
concluded that Rachel's claim must fail, and the DENR must
conduct a thorough investigation to resolve the factual issues
raised by her protest.