GR 214587; (February, 2018) (Digest)
G.R. No. 214587 February 26, 2018
JOSEPHINE P. DELOS REYES and JULIUS C. PERALTA, represented by their Attorney-in-fact, J.F. JAVIER D. PERALTA, Petitioners vs. MUNICIPALITY OF KALIBO, AKLAN, its SANGGUNIANG BAYAN and MAYOR RAYMAR A. REBALDO, Respondents
FACTS
The petitioners, heirs of Jose Peralta, claimed ownership over parcels of land adjacent to the Aklan River, asserting these were accretions to their titled property, Lot 2076-A. The land was originally occupied by their tenant, Ambrocio Ignacio, who executed a quitclaim in favor of Jose Peralta in 1955. The property was subsequently declared for taxation in the names of the petitioners. In the 1990s, the Municipality of Kalibo sought to establish a garbage dumpsite on the contested area, claiming it was part of the public domain. Despite the petitioners’ written oppositions, the municipality proceeded with construction, enclosing the area with a perimeter fence. The petitioners filed a complaint for quieting of title. The Regional Trial Court ruled in their favor, declaring the land as accretion and ordering the municipality to cease occupation.
ISSUE
The main issue is whether the Court of Appeals erred in reversing the RTC and declaring the subject properties as part of public land, thereby dismissing the action for quieting of title.
RULING
The Supreme Court denied the petition and affirmed the CA decision. The Court held that an action for quieting of title requires the plaintiff to have a legal or equitable title to, or interest in, the disputed property. The petitioners failed to establish such title. While the adjacent Lot 2076-A was registered under the Torrens system, the claimed accretion itself was never registered. The Court emphasized that ownership of accretion, governed by the Civil Code, is distinct from registration under the Torrens system. Registration does not vest title but merely confirms a pre-existing title. For the accretion to enjoy the protection of imprescriptibility, it must be placed under the operation of the registration laws through the proper judicial procedures, which the petitioners did not accomplish. Furthermore, the petitioners did not sufficiently prove by preponderance of evidence that the increment was indeed formed through accretion, a process requiring gradual and imperceptible addition caused by the current of the river. The municipality’s possession and development of the land for a public purpose underscored the absence of the petitioners’ registrable title. Consequently, with no valid title or interest demonstrated, there was no cloud on title to be removed, and the action for quieting of title could not prosper.