Canlas vs.

Republic Ruling:
G.R. No. 200894
Nov 10, 2014 The Supreme Court granted the petition,
reversing the decisions of the Court of Appeals
Petitioner sought land registration, proving and remanding the case to the trial court for
possession since 1945. SC reversed CA, remanded further proceedings regarding the determination
to trial court to verify inclusion in TCT No. 23377. of whether the land described in plan
Psu-04-006561 is included in TCT No. 23377.

Facts:
Ratio:
The case involves Luzviminda A. Canlas
(petitioner) and the Republic of the Philippines The Supreme Court emphasized that the issue of
(respondent). On August 22, 2006, Canlas sufficiency of evidence is generally factual and
applied for the original registration of a typically outside the scope of review under Rule
9,751-square-meter parcel of land located in 45 of the Rules of Court. However, exceptions
Barrio Macamot, Municipality of Binangonan, apply when the findings of the trial court and the
Province of Rizal, under Presidential Decree No. Court of Appeals conflict or when the judgment is
1529. The land was technically described as based on a misapprehension of facts. The Court
Cadastral Lot No. 11566, Psu-04-006561. There found that Canlas had sufficiently demonstrated
was no opposition to her application, and the her open, continuous, exclusive, and notorious
Republic did not submit any comment or possession of the land since June 12, 1945, or
opposition despite being given the opportunity by earlier, through various acts of dominion,
the trial court. The Regional Trial Court granted including farming activities, tax declarations, and
Canlas's application on January 30, 2008, stating other evidence of ownership. The Court noted
that she had proven her open, continuous, that the trial court's findings were entitled to
exclusive, and notorious possession of the land for great respect, as it was in a better position to
more than 30 years through her evaluate witness testimonies. The Court also
predecessors-in-interest. The court ordered the clarified that tax declarations are not conclusive
Register of Deeds of Rizal to register the property evidence of ownership but can be considered
in Canlas's name, subject to an easement for alongside other evidence. The Supreme Court
public use. However, the Republic filed a notice of remanded the case to the trial court to ascertain
appeal on February 29, 2008. The Court of the validity of the Land Registration Authority's
Appeals later reversed the trial court's decision, report regarding the inclusion of the land in TCT
asserting that Canlas failed to prove the requisite No. 23377, allowing for a thorough examination
possession and occupation of the property. The of the evidence and ensuring due process for all
appellate court noted that Canlas had not resided parties involved.
on the property since her marriage in 1966 and
contradicted her claims regarding any Heirs of Yusingco vs. Busilak
encumbrances on the land. The Court of Appeals
dismissed her application for registration of title G.R. No. 210504 | Jan 24, 2018
on November 10, 2011, and denied her motion for
reconsideration on February 23, 2012. Canlas Heirs of Yusingco, declared lawful owners,
then filed a petition for review on certiorari before recover possession from intruders despite prior
the Supreme Court. judgments not directly involving respondents.

Issue: Facts:
1.​ Has Luzviminda A. Canlas proven open, The case involves the petitioners, the Heirs of
continuous, exclusive, and notorious Alfonso Yusingco, represented by their
possession and occupation of the land attorney-in-fact, Teodoro K. Yusingco, against the
described in plan Psu-04-006561? respondents Amelita Busilak, Cosca Navarro,
2.​ Is the land covered by TCT No. 23377, Flavia Curayag, and Lexberto Castro. The events
wherein Canlas is one of the bona fide leading to the case began on August 11, 2005,
occupants whose possession and when the petitioners filed five separate
occupation ripened into an indefeasible complaints for accion publiciana and/or recovery
right to title? of possession against the respondents and a
certain Reynaldo Peralta in the Municipal Trial
Court in Cities (MTCC), Branch 1, Surigao City.
The petitioners claimed ownership of three
parcels of land located in Barangay Taft, Surigao
City, which they inherited from their
predecessor-in-interest, Alfonso Yusingco. They Ratio:
asserted that they had been in possession of these
properties prior to World War II but lost The Supreme Court emphasized that the actions
possession during the war. Upon returning, they filed by the petitioners were indeed for accion
found the properties occupied by various reivindicatoria, not merely for recovery of
individuals, including the respondents, who possession. The Court clarified that a judgment in
entered the properties without the petitioners' an accion reivindicatoria determines ownership
consent. The petitioners had previously filed cases and awards possession to the lawful owner, which
for recovery of possession against other is binding on the parties involved. The Court
occupants, which were decided in their favor, noted that the judgments in the previous cases,
declaring them the lawful owners of the which declared the petitioners as the lawful
properties. Despite this, the respondents refused owners of the properties, were in personam and
to vacate the premises after being demanded to do thus binding only on the parties properly
so. impleaded. However, the Court recognized an
exception where non-parties, such as the
respondents, could be bound by the judgment if
In their defense, the respondents claimed they
they were trespassers or intruders on the
had been in possession of the properties for over
property.
thirty years and argued that the petitioners never
had actual possession or title over the land. After
the trial, the MTCC ruled in favor of the The Court found that the respondents were
petitioners on February 25, 2011, ordering the indeed intruders without any legitimate claim to
respondents to vacate the properties and pay the properties, as they had occupied the land
monthly compensation for their use of the land. without the petitioners' consent and had not
The Regional Trial Court (RTC), Branch 30, established any legal basis for their possession.
Surigao City, affirmed this decision with The evidence presented showed that the
modifications on August 17, 2011. However, the respondents were aware of the petitioners'
respondents appealed to the Court of Appeals ownership and had no right to possess the
(CA), which, on July 31, 2013, granted their properties. Therefore, the Court concluded that
petition, set aside the RTC's decision, and the CA erred in dismissing the petitioners' claims
dismissed the consolidated cases for lack of merit. based on the previous judgments, which were
The CA ruled that the previous judgments binding on the respondents as they were found to
declaring the petitioners as owners did not bind be mere trespassers. The Court reinstated the
the respondents since they were not parties to MTCC's ruling, affirming the petitioners' right to
those actions. recover possession of the properties.

Miranda vs. Spouses Mallari

Issue:
1.​ Are the final and executory decisions G.R. No. 218343 | Nov 28, 2018
rendered in a previous accion
reivindicatoria, which found the Spouses Mallari won damages, levied property
petitioners to be the lawful owners of the sold at auction, but Miranda claimed prior
subject properties, binding upon the unregistered sale. SC ruled Miranda had better
respondents? possession rights, invalidating execution sale.
2.​ Did the Court of Appeals err in ruling that
the prior judgments did not bind the
respondents, as they were not parties to Facts:
the actions?
The case involves Jun Miranda as the petitioner
and Spouses Engr. Ernesto and Aida Mallari,
Ruling: along with Spouses Domiciano C. Reyes and
The Supreme Court ruled in favor of the Carmelita Pangan, as respondents. The events
petitioners, granting the petition for review on leading to the case began with a decision rendered
certiorari. The Court reversed and set aside the on January 24, 2000, by the Regional Trial Court
July 31, 2013 Decision of the Court of Appeals and (RTC) of Balanga City in Civil Case No. 6701,
reinstated the Omnibus Judgment of the which ordered the Spouses Reyes to pay damages
Municipal Trial Court in Cities, Branch 1, Surigao to the Spouses Mallari. The decision became final
City, dated February 25, 2011. and executory on February 20, 2002, and was
annotated on Transfer Certificate of Title (TCT)
No. NT-266485. Following this, a Writ of
Execution was issued, leading to a public auction
on September 12, 2003, where the Spouses
Mallari purchased the subject property, a Since the Spouses Reyes had sold the property to
7.3-hectare lot located in Barangay Papaya, San Miranda in 1996, they had no interest to transfer
Antonio, Nueva Ecija, for PhP 1,645,000.00. during the execution sale. The Court cited the
principle that a duly registered levy on
On March 3, 2004, the Spouses Mallari filed a suit attachment or execution takes precedence only
for recovery of possession against Jun Miranda, when the ownership has not already vested in a
who claimed to have purchased the property from prior unregistered sale. The Court concluded that
the Spouses Reyes in 1996. Miranda argued that Miranda's claim of ownership, supported by the
he was the rightful owner despite not registering actual possession of the property, was valid, and
the sale due to losing the owner's copy of the title. thus he had a better right to possession than the
He contended that the Spouses Mallari had no Spouses Mallari, who were merely claimants from
cause of action against him as they were merely an execution sale. The Court's ruling was limited
claimants from an execution sale. Miranda also to the issue of possession and did not constitute a
filed a third-party complaint against the Spouses final determination of ownership, allowing for
Reyes, asserting that they should be liable for any future actions regarding ownership to be pursued
damages he incurred due to the eviction. The RTC by either party.
ruled in favor of the Spouses Mallari on June 3,
2010, ordering Miranda to surrender possession Javelosa vs. Tapus
of the property and dismissing his third-party
complaint. Miranda's appeal to the Court of G.R. No. 204361 | Jul 4, 2018
Appeals was denied, leading to the current
petition for review on certiorari. Petitioner, owner of Boracay land, failed to prove
respondents' initial lawful possession based on
tolerance, rendering unlawful detainer improper;
Issue: SC affirmed dismissal, suggesting other remedies.
1.​ Did the Court of Appeals err in upholding
the rights of the Spouses Mallari as
Facts:
attaching creditors despite their
knowledge of the prior unregistered sale to The case involves Cecilia T. Javelosa (petitioner),
Miranda? represented by her attorney-in-fact Ma. Diana J.
2.​ Did the Court of Appeals err in not Jimenez, against respondents Ezequiel Tapus,
awarding damages to Miranda? Mario Madriaga, Danny M. Tapuz, Juanita Tapus,
3.​ Did the Court of Appeals err in dismissing and Aurora Madriaga. The dispute centers around
Miranda's third-party complaint against a parcel of land located at Sitio Pinaungon,
the Spouses Reyes? Barangay Balabag, Boracay Island, Malay, Aklan,
4.​ Did the Court of Appeals err in not which is covered by Transfer Certificate of Title
reconsidering its decision despite (TCT) No. T-35394. The petitioner acquired the
compelling reasons for its reversal? property through a donation from her
predecessor-in-interest, Ciriaco Tirol. The
respondents claim that their predecessors were
Ruling: caretakers of the property and that they have
The Supreme Court partly granted Miranda's occupied it with the permission of Tirol.
petition, reversing the decisions of the Court of
Appeals and the RTC. The Court held that In 2003, the petitioner’s daughter discovered that
Miranda had a better right of possession over the the respondents were attempting to sell the
subject property, having acquired ownership prior property, prompting the petitioner to send a
to the levy on execution. The Court did not demand letter for them to vacate the premises,
address the issues regarding damages or the which they ignored. Consequently, the petitioner
dismissal of the third-party complaint as they filed a case for unlawful detainer. The
were rendered superfluous by the primary ruling. respondents countered by asserting that they had
occupied the property for over 60 years and
claimed ownership, alleging that the petitioner’s
Ratio: title was spurious.
The Supreme Court reasoned that the right of the
Spouses Mallari, as attaching creditors, could not The Municipal Circuit Trial Court (MCTC) ruled
prevail over Miranda's ownership of the property in favor of the petitioner, affirming her ownership
acquired through a valid sale, even if and ordering the respondents to vacate the
unregistered. The Court emphasized that a property and pay monthly rentals. The Regional
judgment debtor can only transfer property in Trial Court (RTC) upheld the MCTC's decision.
which they have an interest at the time of the levy. However, the Court of Appeals (CA) later reversed
these rulings, stating that the petitioner failed to
prove that the respondents' possession was
initially lawful and based on her tolerance. The
CA dismissed the case for unlawful detainer, Facts:
leading the petitioner to file a Petition for Review The case involves the Heirs of Flores Restar,
on Certiorari before the Supreme Court. namely Esmenia R. Restar, Bernardita R.
Rentino, Lucia Restar, Rodolfo Restar, Janet R.
Issue: Relojero, Lorna R. Ramos, Manuel Restar, Nenita
R. Belleza, Mirasol R. Dela Cruz, Roselle R.
Did the Court of Appeals err in dismissing the Matorre, Policarpio Restar, and Adolfo Restar as
case for unlawful detainer filed by the petitioner petitioners, against the Heirs of Dolores R.
against the respondents? Cichon, Perpetua R. Sta. Maria, and Maria R.
Rose as respondents. The events trace back to
1935 when Emilio Restar died intestate, leaving
Ruling: behind eight children, including Flores Restar. In
The Supreme Court denied the petition for lack of 1960, Flores Restar, based on a Joint Affidavit
merit, affirming the decision of the Court of executed with Helen Restar, canceled Tax
Appeals which dismissed the unlawful detainer Declaration No. 6696 in Emilio's name for a 5,918
case. square meter parcel of land located in Barangay
Carugdog, Lezo, Aklan, and secured a new Tax
Declaration No. 11134 in his name. Flores passed
Ratio: away on June 10, 1989. On November 5, 1998, his
co-heirs discovered the cancellation of the
The Supreme Court emphasized that in an original tax declaration and the issuance of the
unlawful detainer action, the petitioner must new one. Consequently, on January 21, 1999, the
prove that the respondent's initial possession was heirs of Flores' sisters filed a complaint for
lawful and based on the petitioner's permission or partition, declaration of nullity of documents,
tolerance. The Court noted that the petitioner ownership with damages, and a preliminary
failed to provide sufficient evidence to establish injunction against Flores' heirs in the Regional
that the respondents' occupation of the property Trial Court (RTC) of Aklan. The plaintiffs claimed
was initially lawful. The absence of proof they had received shares of produce from the lot
regarding the nature of the respondents' entry and that after Flores' death, his widow requested
and the lack of details on how and when to hold onto the lot for the education of their
permission was granted were critical children, with an agreement to partition it later.
shortcomings in the petitioner's case. The defendants, however, asserted that they had
possessed the lot for over thirty years and denied
The Court reiterated that mere allegations are not any agreement regarding the partition. The RTC
equivalent to proof, and the burden of ruled in favor of the defendants, stating that
establishing the essential jurisdictional facts lies Flores had repudiated the co-ownership and
with the petitioner. The ruling highlighted that acquired the lot by prescription. The appellate
the owner of a property cannot simply reclaim court later reversed this decision, leading to the
possession through an unlawful detainer action present petition.
without proving the necessary elements,
particularly the fact of tolerance. The Court also
clarified that the mere failure to eject the Issue:
occupants does not imply tolerance, as tolerance
1.​ Did the petitioners, as heirs of Flores
must be accompanied by permission.
Restar, acquire ownership of the lot by
adverse possession?
In conclusion, the Supreme Court upheld the CA's 2.​ Was there a valid repudiation of
ruling, reinforcing the principle that an action for co-ownership by Flores Restar that would
unlawful detainer requires clear evidence of prior allow for the acquisition of ownership
lawful possession and the owner's tolerance, through prescription?
which the petitioner failed to demonstrate.

Heirs of Restar vs. Heirs of Cichon Ruling:

The Supreme Court granted the petition,
G.R. No. 161720 | Nov 22, 2005
reversing the appellate court's decision and
reinstating the RTC's ruling that the petitioners
Heirs of Flores acquired Lot 3177 by extraordinary
had acquired ownership of the lot by
prescription after 39 years of adverse possession,
extraordinary prescription.
barring co-heirs' partition claim due to laches.
Ratio: Cebu filed a motion for a new trial, arguing that
the decision was contrary to the evidence and the
The Court emphasized that under Article 494 of law, which was denied. The Municipality then
the New Civil Code, no co-owner is obliged to appealed to the higher court. The land in question
remain in co-ownership, and each may demand was situated south of the seminary's church, and
partition of the property. However, a co-owner the Municipality contended that the land claimed
may acquire ownership through prescription if by the Seminary did not extend into the public
there is a clear repudiation of co-ownership and plaza, as there was a well-defined boundary
the other co-owners are aware of the adverse marked by an iron fence separating the two
claim. The Court found that the petitioners had properties. The Seminary presented historical
met the requirements for extraordinary documents to support its claim, while the
prescription, as Flores Restar had taken Municipality maintained that the land described
possession of the lot and exercised acts of in the Seminary's title did not include any part of
dominion over it since 1960, when he secured the the plaza.
tax declaration in his name. The Court noted that
the respondents had not asserted their claim until
1999, indicating their lack of possession and Issue:
acknowledgment of Flores' adverse claim. The
Court also highlighted that the respondents' 1.​ Does the land claimed by the Seminary of
claims of receiving shares from the produce were San Carlos extend into the public plaza of
not credible and did not negate the petitioners' Cebu City?
adverse possession. The evidence supported that 2.​ What is the correct interpretation of the
Flores had effectively repudiated the boundaries and measurements of the land
co-ownership through his actions, including the as described in the Seminary's title
cancellation of the tax declaration and the documents?
payment of taxes, which were acts inconsistent 3.​ Can the Municipality of Cebu claim
with co-ownership. Thus, the petitioners' ownership of the land based on
continuous and exclusive possession for over prescription despite the Seminary's
thirty years constituted ownership by historical title?
extraordinary prescription.
Ruling:
Seminary of San Carlos vs. Municipality of
Cebu 1.​ The court ruled that the land claimed by
the Seminary does extend into the public
G.R. No. L-4641 | Mar 13, 1911 plaza.
2.​ The court found that the measurements
Seminary claims land including plaza; city asserts and boundaries described in the
adverse possession. Court rules seminary owns Seminary's title documents were valid and
land, city’s use permissive under 1869 agreement. included portions of the public square.
3.​ The court concluded that the Municipality
of Cebu could not claim ownership based
on prescription due to the nature of its
Facts: possession being permissive rather than
adverse.
The case involves the Seminary of San Carlos,
represented by its rector, Pedro Julia, as the
petitioner and appellee, against the Municipality Ratio:
of Cebu, which is the opponent and appellant. The
case was decided on March 13, 1911, concerning The court's decision was based on a thorough
the registration of two parcels of land located in examination of the historical documents
Cebu City. The Seminary of San Carlos claimed presented by the Seminary, which included royal
ownership of the land based on a royal cession decrees and descriptions of the land that clearly
from the King of Spain, asserting that the land indicated its boundaries. The court noted that the
included a portion of a public square in the city. land described in the Seminary's title exceeded
The Municipality of Cebu contested this claim, the area that could logically fit between the
asserting its ownership based on long-term church and the iron fence, thus confirming that it
possession sufficient to establish title by must extend into the public plaza. The court
prescription. emphasized that the descriptions in the title
documents were consistent and supported by the
In the lower court, the Seminary was successful, evidence presented, including a plan that
with a judgment declaring it the owner of the land illustrated the land's location.
and ordering its registration. The Municipality of
Regarding the Municipality's claim of ownership property and pay damages. Caraan appealed the
through prescription, the court found that the decision to the Court of Appeals, which, on
Municipality's possession was initiated and October 29, 1999, affirmed the RTC's ruling but
maintained under the direction of the political modified the damages awarded. Following
and military governor of Cebu, which indicated Caraan's death, his heirs filed a petition for review
that such possession was permissive and not on certiorari, asserting that the private
adverse. The court cited provisions from the Civil respondents' title was invalid and that Caraan had
Code that state possession must be public, a better right to the property due to his long
peaceful, and uninterrupted to establish a possession.
prescriptive title. Since the Municipality's
possession was characterized by acknowledgment
of the Seminary's rights, it could not be used as a Issue:
basis for claiming ownership. Consequently, the 1.​ Is the private respondents' TCT No.
court modified the lower court's judgment to 214949 valid and can it be collaterally
affirm the Seminary's title while recognizing the attacked in this case?
Municipality's right to possess and use the land 2.​ Did Dionisio Caraan acquire ownership of
for public purposes as long as it remained the property through extraordinary
dedicated to such use. prescription despite the private
respondents' title?
Caraan vs. Court of Appeals 3.​ Can the petitioners' claim of possession for
over thirty years prevail over the
G.R. No. 140752 | Nov 11, 2005 registered title of the private respondents?

Ruling:
Facts:
The Supreme Court denied the petition for lack of
The case involves Dionisio Caraan, represented by merit and affirmed the Decision of the Court of
his heirs Heidi Caraan and Erlinda Caraan, as the Appeals dated October 29, 1999. The Court held
petitioner against the Court of Appeals and that the private respondents' certificate of title is
spouses Salcedo R. Cosme and Nora Linda S. valid and cannot be collaterally attacked in this
Cosme, the respondents. The events leading to action. Furthermore, the Court ruled that
this case began on September 16, 1992, when the Caraan's claim of ownership through
private respondents filed a complaint for accion extraordinary prescription was baseless, as
reivindicatoria with damages against Dionisio registered land cannot be acquired by
Caraan in the Regional Trial Court (RTC) of prescription.
Quezon City, Branch 104. The private
respondents claimed to be the registered owners
of a property located at No. 65 Commodore St., Ratio:
Veterans Subdivision, Barangay Holy Spirit, The Court emphasized that a certificate of title
Quezon City, under Transfer Certificate of Title serves as conclusive evidence of ownership and
(TCT) No. 214949. They asserted that they had cannot be subject to collateral attack, as
been paying realty taxes on the property since established in Section 48 of Presidential Decree
1969 and discovered in March 1991 that Caraan No. 1529. The private respondents successfully
was occupying the land without their consent. presented TCT No. 214949, which shifted the
Despite several demands to vacate, including a burden of proof to the petitioners to demonstrate
final written demand on August 7, 1992, Caraan a better right to the property. The petitioners'
refused to leave. The private respondents sought a claims regarding the alleged invalidity of the
court order for Caraan to vacate the premises, private respondents' title were deemed collateral
along with compensation for use and occupancy, attacks, which are impermissible in actions for
moral damages, and attorney's fees. recovery of possession. The Court reiterated that
registered land cannot be acquired through
In his answer, Caraan contended that he had adverse possession, as stated in Section 47 of P.D.
acquired the property through extraordinary No. 1529. The petitioners' assertion of continuous
prescription, claiming continuous and possession for over thirty years was insufficient to
uninterrupted possession for over thirty years. He overcome the private respondents' registered title,
also argued that the private respondents' title was which is the best proof of ownership.
derived from a series of titles that were declared Consequently, the Court ruled that the private
null and void by the RTC. After a trial, the RTC respondents were entitled to possession of the
ruled in favor of the private respondents on property.
August 9, 1995, ordering Caraan to vacate the
 Ruling:
The Supreme Court affirmed the orders of the
Tamparong vs. Nery
lower court, rejecting Casimiro Tamparong's
claims for the payment of P6,045 against the
G.R. No. 46345 | Dec 16, 1938 estate of Filomeno Nery Velez. The court held that
the claims were filed too late and that
Tamparong's actions in pursuing multiple claims
Tamparong's claims against Velez's estate were for the same credits were not permissible under
rejected for being filed late and pursuing multiple the law.
legal actions for the same credits, violating
procedural laws.
Ratio:
Facts: The court's decision was grounded in the
provisions of Act No. 190, specifically section 708,
The case involves Casimiro Tamparong as the which prohibits a creditor from pursuing multiple
claimant and appellant against Roque V. Nery, the actions for the same claim after one has been
administrator and appellee, in the intestate estate decided. The court noted that Tamparong had
of the deceased Filomeno Nery Velez. Filomeno previously filed separate cases regarding the same
Nery Velez passed away on September 3, 1931, credits, which had been resolved against him. The
and intestate proceedings commenced on March law allows a creditor to choose between filing a
26, 1932, in the Court of First Instance of Oriental claim in intestate proceedings or pursuing an
Misamis. Roque V. Nery was appointed as the ordinary action, but not both simultaneously.
administrator of the estate, and a committee was Furthermore, the court highlighted that
established to appraise the property and decide Tamparong failed to comply with the time limits
on claims against the estate. Casimiro Tamparong set by law for reproducing his claims after the
filed his claims for the first time on July 7, 1936, administrator's appeal, as he did not act within
seeking payment of P6,045, which he alleged were the required thirty-day period following the notice
amounts owed to him from two loans made to the of appeal. Thus, the court concluded that both the
deceased during his lifetime. The first claim was rejection of his claims and the affirmation of the
for P4,000 based on a document he claimed was a lower court's orders were justified and
mortgage, while the second claim was for P2,225, well-founded.
which included a promissory note executed by the
deceased on March 24, 1931. The committee on Heirs of Navarro vs. Intermediate
claims and appraisal initially approved Appellate Court
Tamparong's claims on November 12, 1932, and
March 11, 1933. However, the administrator
G.R. No. 68166 | Feb 12, 1997
appealed these decisions on March 22, 1933.
Subsequently, Tamparong filed a separate case
Disputed land ruled as foreshore, part of public
(No. 4231) on May 23, 1933, to recover the
domain, not private accretion; Supreme Court
P4,000 mortgage credit, which was decided
reversed appellate decision, reinstating trial
against him in early 1933 for being premature. He
court's dismissal.
later abandoned this claim to focus on the P2,225
credit. Despite the committee's approval of his
claims in 1935, Tamparong failed to timely
reproduce his claim after the administrator's Facts:
appeal, leading to the lower court rejecting his
claim on the grounds of being filed too late. The The case involves the Heirs of Emiliano Navarro
court affirmed this decision upon Tamparong's as petitioners and the Intermediate Appellate
motion for reconsideration. Court and the Heirs of Sinforoso Pascual as
respondents. The events leading to the case began
on October 3, 1946, when Sinforoso Pascual filed
Issue: an application for a foreshore lease covering
approximately 17 hectares of land in Sibocon,
1.​ Did the lower court err in rejecting
Balanga, Bataan. This application was denied on
Casimiro Tamparong's claim for the
January 15, 1953, along with his motion for
payment of P6,045 against the estate of
reconsideration. Subsequently, Emiliano Navarro,
Filomeno Nery Velez?
the petitioners' predecessor-in-interest, applied
2.​ Was the claim filed by Tamparong within
for a fishpond permit covering 25 hectares of
the prescribed time limits set by law?
foreshore land in the same area. Initially denied,
the application was later granted for 7 hectares
after a reconsideration by the Director of
Fisheries, despite opposition from the Municipal and the land must be adjacent to the river bank.
Council of Balanga. In this case, the disputed land was adjacent to
Manila Bay, not a river, which disqualified it from
In the early 1960s, Sinforoso Pascual filed an being classified as an accretion.
application to register a parcel of land, claiming it
as an accretion to his property, which was The Court noted that the evidence presented
adjacent to the Talisay River, Bulacan River, and indicated that the land was formed by the action
Manila Bay. The Director of Lands opposed this of the sea, specifically the Manila Bay, rather than
application, asserting that the land was public the Talisay and Bulacan Rivers. The planting of
domain. However, the Director of Lands later trees by Pascual was deemed insufficient to
withdrew the opposition, leaving the Director of establish that the land was formed by the rivers'
Forestry as the sole oppositor. Emiliano Navarro action. The Court also referenced the Spanish Law
subsequently filed an opposition to Pascual's of Waters of 1866, which states that lands added
application, asserting that the land was part of the to the shores by accretions caused by the action of
public domain and that he had a fishpond permit the sea are part of the public domain. Thus, the
for a portion of it. disputed land was determined to be public land,
not subject to private ownership or registration
During the proceedings, Pascual also filed an without proper governmental declaration.
ejectment complaint against Navarro and others,
claiming unlawful possession of the property. The
trial court ruled in favor of Navarro, determining
that the land was foreshore and part of the public
domain, thus not subject to registration. The heirs
of Pascual appealed this decision, arguing that the
land was an accretion formed by the rivers. The
Intermediate Appellate Court reversed the trial
court's decision, granting the registration of the
land but excluding certain portions. The case
eventually reached the Supreme Court, which had
to determine the nature of the land in question.

Issue:
1.​ Is the land sought to be registered by the
heirs of Sinforoso Pascual an accretion
that naturally accrues to the riparian
owner, or should it be classified as
foreshore land?
2.​ Did the Intermediate Appellate Court err
in reversing the trial court's decision
regarding the nature of the land?

Ruling:
The Supreme Court ruled in favor of the
petitioners, the Heirs of Emiliano Navarro,
reversing the decision of the Intermediate
Appellate Court. The Court reinstated the trial
court's ruling that the disputed land is foreshore
land and part of the public domain, thus not
subject to private ownership or registration.

Ratio:
The Supreme Court's decision was grounded in
the interpretation of the nature of the land in
question. The Court emphasized that for land to
be considered an accretion under Article 457 of
the Civil Code, it must be formed by the gradual
and imperceptible action of the waters of a river,