G.R. No. L-52772 May 16, 1983
ESCAÑO HERMANOS INCORPORADO., petitioner vs. COURT OF APPEALS, HON. ARTURO R. TANCO, JR., et al., respondents.

FACTS

The petitioner, Escaño Hermanos Incorporado, holds a title to a 1,023-hectare agricultural land in Bukidnon, originally acquired through a sales application and patent from the government. The northern boundary of this titled land was described in the patent and subsequent certificates of title as “Paitan Creek and public land.” However, the corporation’s possession of a specific 62-hectare strip, bounded on the north by the Paitan Creek, was challenged by other occupants. These occupants complained to the Secretary of Agriculture and Natural Resources, who ordered a relocation survey.
The survey, conducted by geodetic engineer Laureano Ledres, revealed a critical discrepancy. It found that the correct natural northern boundary for a large portion of the petitioner’s titled property was actually the Alom Creek, which lies south of the Paitan Creek. Consequently, the 62-hectare strip situated between the Alom Creek and the Paitan Creek was determined to be outside the metes and bounds of the petitioner’s titled land and, therefore, part of the public domain. Based on this report, the Secretary directed the subdivision and distribution of the 62 hectares to the actual occupants, prompting the petitioner to file a prohibition case.

ISSUE

The core issue is whether the 62-hectare strip of land is included within the boundaries of the titled property of Escaño Hermanos Incorporado.

RULING

The Supreme Court affirmed the ruling of the Court of Appeals, holding that the 62-hectare land is not part of the petitioner’s titled property. The Court deferred to the factual findings established by the official relocation survey. The legal logic rests on the principle that the technical description in a title, which defines the property’s metes and bounds, is controlling. The Ledres survey demonstrated a material error in the original description regarding the northern boundary. While the patent and title referenced “Paitan Creek,” the actual survey of the ground established that the property’s limits, as defined by its corners and lines, reached only to the Alom Creek.
The Court found the survey report to be credible and noted that the petitioner, when given the opportunity by the trial court to commission its own surveyors to verify the “tie line” or connection points of the property, opted instead to move for a summary judgment. This was construed as a waiver of the right to contest the technical findings through a contrary survey. Furthermore, the Court distinguished a prior favorable decision from the Bukidnon Court of First Instance, as it involved different parties and notably did not consider the Ledres survey report. Thus, the official survey finding that the land’s actual boundaries were limited by the Alom Creek prevailed, rendering the disputed strip public land subject to distribution by the state.