G.R. No. 30829 , August 28, 1929
THE GOVERNMENT OF THE PHILIPPINE ISLANDS vs. COLEGIO DE SAN JOSE

FACTS

The Government of the Philippine Islands appealed a decision of the Court of First Instance of Laguna ordering the registration of two parcels of land (Lots 1 and 2) in favor of Colegio de San Jose. The government claimed the lands were part of the bed of Laguna de Bay and thus belonged to the public domain. The evidence showed that the lands were covered by the lake’s waters during the rainy season (September to November) but were dry and cultivated during the dry season (December to August). Colegio de San Jose claimed the lands as part of its Hacienda de San Pedro Tunasan, based on immemorial possession through its tenants.

ISSUE

Whether the two parcels of land belong to the public domain as part of the bed of Laguna de Bay or are private property owned by Colegio de San Jose.

RULING

The Supreme Court affirmed the lower court’s decision, ruling in favor of Colegio de San Jose. The Court held that Laguna de Bay is a lake, and its natural bed or basin is defined by the highest ordinary depth of its waters. The ordinary high water level occurs during the nine dry months, not during the three-month rainy season when the inundation is extraordinary. Since the disputed lands are only covered by water during the extraordinary floods of the rainy season, they are not part of the lake’s bed. Consequently, the lands remain the private property of Colegio de San Jose, whether considered as part of its hacienda accidentally inundated or as alluvial formations by accession belonging to the riparian owner. The provisions on sea shores under the Law of Waters do not apply to lakes.