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MENESES vs. CA Et Al G.R. No. 82220 July 14, 1995 Facts

This case involves a land dispute between the Meneses brothers and the Quisumbing family over property along Laguna de Bay. The trial court and Court of Appeals both found that the lands occupied by the Meneses brothers were accretion lands that rightfully belonged to the Quisumbings as the owners of the adjacent riparian land. The Supreme Court affirms this decision, finding that the lands are not public lands and that the Meneses brothers conspired to fraudulently obtain free patents and titles to the property.

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139 views

MENESES vs. CA Et Al G.R. No. 82220 July 14, 1995 Facts

This case involves a land dispute between the Meneses brothers and the Quisumbing family over property along Laguna de Bay. The trial court and Court of Appeals both found that the lands occupied by the Meneses brothers were accretion lands that rightfully belonged to the Quisumbings as the owners of the adjacent riparian land. The Supreme Court affirms this decision, finding that the lands are not public lands and that the Meneses brothers conspired to fraudulently obtain free patents and titles to the property.

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melbertgutzby vivas
Copyright
© © All Rights Reserved
We take content rights seriously. If you suspect this is your content, claim it here.
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MENESES  vs.

CA et al
G.R. No. 82220
July 14, 1995
FACTS: On March 1, 1977, Darum, then the District Land Officer of Los
Baños, Laguna, issued to Pablito Meneses 2 Free Patent and 2 OCT
covering lots located in Los Baños, Laguna.
Pablito acquired said property from Bautista through a Deed of Waiver and
Transfer of Rights executed in 1975 in consideration of Bautista’s “love and
affection” for and “some monetary obligations” in favor of Meneses. After
the execution of said document, Meneses took possession of the land,
introduced improvements thereon, declared the land as his own for tax
purposes and paid the corresponding realty taxes. In turn, Bautista
acquired the land from his aunt. He had been occupying the land since
1956.

On the other hand, the Quisumbing family traces ownership of their land as
far back as 1919 when their matriarch was issued an OCT covering a lot,
with the Laguna de Bay as its northwestern boundary. The same parcel of
land was registered on 1973 under a TCT in the names of her heirs, all
surnamed Quisumbing.

The Quisumbings applied for registration and confirmation of title over an


additional area which had gradually accrued to their property by the
natural action of the waters of Laguna de Bay. The CFI of Biñan confirmed
the Quisumbings’ title thereto.

In 1979, the Quisumbings filed a case before the CFI of Calamba against
Lorenzo and Pablito Meneses, Darum and Almendral for nullification of the
free patents and titles issued to Pablito Meneses. They alleged that Lorenzo
Menesis, then the Mayor of Los Baños, using his brother Pablito as a “tool
and dummy,” illegally occupied their “private accretion land” and
confederating with District Land Officer Darum and Land Inspector
Almendral, obtained free patents and OCTs to the land.
In 1984, the trial court rendered the decision finding that the lands
registered by the Meneses brothers are accretion lands to which the
Quisumbings have a valid right as owners of the riparian land to which
nature had gradually deposited the disputed lots. (The lots occupied by
Meneses, as found by the court, are to be accretion lands forming parts of
the bigger accretion land owned by the Quisumbings. )
Meanwhile, the Meneses brothers and Darum appealed the to the CA,
which affirmed in toto the lower court’s decision.The defendants-appellants
filed two MRs of the CA decision but it was denied, hence this petition for
review on certiorari.

ISSUE: WON
1. The lands in question were not accretion lands but lands of the public
domain

2. Conspiracy to commit fraud, deceit and bad faith attended the issuance
of the free patent and titles to Pablito Meneses; and

HELD: WHEREFORE, the petition is DENIED. The Decision CA is


AFFIRMED
 

While the lots occupied by Villamor and Lanuzo may not be the very same
lots petitioners are claiming here, the two cases refer to the same accretion
lands northwest of the original land owned by the Quisumbings.

1. The submersion in water of a portion of the land in question is due to the


rains “falling directly on or flowing into Laguna de Bay from different
sources.” Since the inundation of a portion of the land is not due to “flux
and reflux of tides” it cannot be considered a foreshore land. The land
sought to be registered not being part of the bed or basin of Laguna de
Bay, nor a foreshore land as claimed by the Director of Lands, it is not a
public land and therefore capable of registration as private property
provided that the applicant proves that he has a registerable title.
 

Additionally, the provision of the law on waters will govern in determining


the natural bed or basin of the lake. And accordingly, to Art. 84 of the Law
of Waters of August 3, 1866:
Accretions deposited gradually upon land contiguous to creeks, streams,
rivers and lakes by accessions or sediments from the waters thereof, belong
to the owners of such lands.

As pointed out by the lower court, no act of appropriation is necessary in


order to acquire ownership of the alluvial formation as the law does not
require the same.

2. As found by the CA, petitioners conspired in the approval and grant of the


free patents heirs Quisumbing. Such fraud was confirmed by this Court in
Meneses v. People, which held the petitioners therein liable for violation of
the Anti-Graft and Corrupt Practices Act in the issuance of the same free
patents and titles. In due course, the Sandiganbayan rendered a decision
finding the defendants guilty as charged. The judgment of conviction was
affirmed.

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