#13 REPUBLIC VS. LAT VDA.
DEL CASTILLO
G.R. No. L-69002 June 30, 1988
FACTS:
In 1951, the late Modesto Castillo (Castilo) applied for the registration of two parcels of land,
Lots 1 and 2. The Land Registration Court rendered a decision and declared Castillo as the true
and absolute owner of the land with the improvements thereon, for which Original Certificate of
Title was issued to him.
After the death of Castillo, defendants Amanda Lat Vda. de Castillo, et al., executed a deed of
partition and assumption of mortgage in favor of Florencio L. Castillo, et al., as a result, new
transfer certificates of title were issued to Florencio Castillo, et al.,
The Republic of the Philippines filed a case for the annulment of the certificates of title issued to
defendants Amanda Lat Vda. de Castillo, on the grounds that said lands had always formed part
of the Taal Lake, washed and inundated by the waters thereof, and being of public ownership, it
could not be the subject of registration as private property.
Defendants argued Lots 1 and 2 have always been in the possession of the Castillo family for
more than 76 years and that their possession was public, peaceful, continuous, and adverse
against the whole world. It also argued that The Republic of the Philippines is already barred by
res judicata.
ISSUES:
WON Lots 1 and 2 are properties of the public domain
RULING:
Yes, Lots 1 and 2 are properties of the public domain.
Citing the case of Ramos v. Pablo, 146 SCRA 24 [1986]; that shores are properties of the public
domain intended for public use (Article 420, Civil Code) and, therefore, not registrable. Thus, it
has long been settled that portions of the foreshore or of the territorial waters and beaches
cannot be registered. Their inclusion in a certificate of title does not convert the same into
properties of private ownership or confer title upon the registrant (Republic v. Ayala y Cia, 14
SCRA, 259 [1965], citing the cases of Dizon, et al. v. Bayona, et al., 98 Phil. 943; and Dizon, et
al. v. Rodriguez, et al., 13 SCRA 704).
In this case, it has been satisfactorily established as found by the trial court, that the properties
in question were the shorelands of Taal Lake during the cadastral survey of 1923. Such fact was
further verified in the Verification-Relocation Survey of 1948 by Engineer Arcenas who
conducted said survey himself.