G.R. No. 272308, February 24, 2025
SILVESTRE CORPUZ, PETITIONER, VS. REPUBLIC OF THE PHILIPPINES, RESPONDENT.

FACTS

The case involves the reversion of lands, found to be part of the old riverbed of the Irene River, to the public domain. The Court of Appeals ordered the reversion, a decision affirmed by the Supreme Court’s ponencia. The subject free patents were issued in favor of petitioner Silvestre Corpuz in 1978. Evidence, including a 1977 NAMRIA Topographic Map, showed that almost the entire area of the subject lots remained submerged in water just a year before the patents were issued. This negated Corpuz’s claim of continuous, open, and exclusive possession and cultivation required under the Public Land Act (Commonwealth Act No. 141), constituting a material misrepresentation warranting cancellation of the patents.

ISSUE

Whether the ownership and alienability of an abandoned riverbed depend on whether the abandonment occurred naturally or through human intervention.

RULING

Yes. The concurring opinion clarifies the legal regime governing ownership of abandoned riverbeds, harmonizing relevant Civil Code provisions. The general rule under Articles 420(1) and 502(1) of the Civil Code is that rivers and their natural beds are property of public dominion and cannot be acquired by prescription unless declared alienable and disposable by the government. However, an exception exists when the abandonment results from a natural change in the river’s course.
1. Under Article 461 of the Civil Code, if a riverbed is abandoned due to a natural change in the course of the waters, ownership of the abandoned bed passes to the owners of the lands occupied by the new course, in proportion to the area they lost.
2. Under Article 58 of the Water Code (P.D. No. 1067), in cases of a sudden change in course, the affected landowners have options to acquire the abandoned bed or restore the river, but the abandoned bed initially belongs to the former owners of the new bed.
3. If the change or abandonment is artificial or due to human intervention (as established in Ronquillo v. Court of Appeals and Celestial v. Cachopero), Article 461 does not apply. The riverbed remains part of the public domain and cannot be privately appropriated absent a government declaration of alienability.
In this case, the concurring opinion agrees with the ponencia that the patents were fraudulently obtained. It further opines that, based on a 2020 Geological Assessment Report cited, the Irene River’s change in course appeared to be artificial, caused by the construction of dikes and other human activities. Therefore, even under the exception, the abandoned riverbed remained inalienable public land.