GR 109111; (June, 2000) (Digest)
G.R. No. 109111 June 28, 2000
Carmelino M. Santiago, Montserrat M. Santiago, Nilda M. Iboleon, Belinda Manahan and Josefina M. Capinpin, petitioners, vs. The Court of Appeals and Metropolitan Waterworks and Sewerage System, respondents.
FACTS
Respondent Metropolitan Waterworks and Sewerage System (MWSS) filed an application for original registration of title over eleven parcels of land in San Mateo, Rizal. MWSS alleged open, continuous, exclusive, and notorious possession under a bona fide claim of ownership since June 12, 1945. Its predecessor had buried a 42-inch steel aqueduct pipeline under the land long before World War II to transport water from Wawa Dam to Balara Filters. Petitioners, represented by various heirs of the Manahan family, filed oppositions claiming ownership of portions of the land, presenting Transfer Certificates of Title and an Original Certificate of Title as proof.
The Regional Trial Court ruled in favor of petitioners, dismissing MWSS’s application. The trial court found that MWSS’s tax declarations were not proof of ownership, that petitioners’ Torrens titles were conclusive, and that MWSS’s possession was not open or continuous as the pipelines were buried and their use was discontinued after 1968. The Court of Appeals reversed this decision, declaring MWSS the owner and allowing registration.
ISSUE
Whether the Court of Appeals erred in reversing the trial court and declaring that MWSS had acquired ownership of the subject parcels of land through prescription.
RULING
The Supreme Court affirmed the decision of the Court of Appeals. The Court held that while factual findings of the Court of Appeals are generally conclusive, a review is warranted when the trial court and the appellate court arrive at conflicting conclusions. The Court found the appellate court’s analysis to be correct.
The legal logic centered on prescription and the nature of MWSS’s possession. First, the Court agreed with the Court of Appeals that the technical descriptions in petitioners’ certificates of title showed their properties were merely adjacent to, and did not overlap, the specific strips of land where MWSS’s pipelines were buried. These strips were excluded from the petitioners’ survey plans. Second, the pipelines were installed on what was then untitled, presumably public land. MWSS’s possession through this infrastructure was open and notorious. The Court took judicial notice that the existence of the pipelines was a matter of public knowledge, indicated by visible markers like “pilapils.” The discontinuance of water flow did not negate possession, as the pipes remained in the ground. Consequently, MWSS’s long-standing, exclusive possession since before the war constituted acquisitive prescription, vesting ownership in it. Petitioners failed to prove their predecessors-in-interest owned the specific buried strips or that MWSS’s use was merely tolerated.
