GR 82220; (July, 1995) (Digest)
G.R. No. 82220, 82251, 83059. July 14, 1995.
PABLITO MENESES and LORENZO MENESES, et al., petitioners, vs. THE HONORABLE COURT OF APPEALS, EDUARDO QUISUMBING, et al., respondents.
FACTS
The Quisumbing family held title to a parcel of land in Los Baños, Laguna, bounded by Laguna de Bay. Over time, accretion formed adjacent to their property. In a prior land registration case (LRC Case No. B-327), the court confirmed the Quisumbings’ title to this accretion, classifying it as an addition to their riparian land. Separately, Pablito Meneses acquired rights to adjacent lots from Silverio Bautista and subsequently obtained free patents and original certificates of title for these lots in 1977 through the assistance of District Land Officer Braulio C. Darum. The Quisumbings filed an action to annul these patents and titles, claiming the lands awarded to Meneses were part of the same accretion area they owned.
ISSUE
The primary issue is whether the free patents and titles issued to Pablito Meneses are valid, or whether the lands covered are accretion belonging to the riparian owners, the Quisumbings.
RULING
The Supreme Court denied the petitions of Meneses and affirmed the nullification of his titles. The legal logic rests on the principle of accretion under Article 457 of the Civil Code, which states that accretions formed by the gradual deposit of soil or sediments from waters belong to the owner of the riparian land. The Court found that the lands in question were accretion to the Quisumbings’ property, as established in the final and executory decision in LRC Case No. B-327. This prior adjudication conclusively settled the nature and ownership of the accretion area. The issuance of titles to Meneses did not override this established right, as the land was not part of the public domain disposable by free patent. Furthermore, the Court noted the presence of fraud in the procurement of the patents, as corroborated by a prior graft conviction (Meneses v. People) involving the same transactions. The defense of indefeasibility of title was unavailing because a title issued over land not subject to disposition is void from the beginning. Consequently, the Quisumbings’ ownership, rooted in the law on accretion and fortified by a prior final judgment, prevailed over the subsequently and fraudulently acquired titles of Meneses.