Meneses vs.

Court of Appeals
G.R. No. 82220/ July 14, 1995
QUIASON

Facts –

Braulio Darum (District Land Officer) issued to Pablito Meneses Free Patent and
Original Certificate of Title of Land in Los Banos, Laguna. Pabilito Meneses acquired said
property from Silverio Bautista in consideration of “Love and Affection” of Bautista to Meneses.
On the other hand, Quisumbing family traces ownership of land and found out that the said land
is covered with the Original Certificate title of their family with Laguna de Bay as its
northwestern boundary. Quisumbings also applied registration for the accrued land to their
property by the natural action of the waters of Laguna de Bay.

RTC Binan confirmed the Quisumbing’s title thereto. Hence, Quisumbings filed for the
nullification of free patents and titles issued to Pablito Meneses. They alleged that Lorenzo
Meneses (Mayor of Los Banos), using his brother Pablito as a “tool and dummy” illegally
occupied their “private accretion land” by obtaining free patents and original certificates of title
to the land.

RTC rendered decision finding that Laguna de Bay is considered as a Lake and the lands
registered by 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. Under
Art. 84 on the Law of Waters, “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.” RTC found out that the free patents issued to Meneses had been procured
through fraud, deceit and bad faith since 1) It lacks consideration; 2) Mayor Lorenzo Meneses
had no authority to notarize deeds of conveyances; 3) Land Inspector confessed that he
anomalously prepared the documents and filled up the blank in absence of the persons
concerned.

Petitioners then went to CA contending that 1) Land in question is not accretion of lands
but lands of public domain; 2) No conspiracy to commit fraud was commited; 3) The Deed and
Transfer of Rights was founded on a valid consideration. CA affirmed RTC decision.

Issue –

1) WoN 1) Land in question is not accretion of lands but lands of public domain; 2) No
conspiracy to commit fraud was commited; 3) The Deed and Transfer of Rights was
founded on a valid consideration.

Ruling –

This Court is limited to reviewing errors of law. The case at hand is evidently a factual
issue to which RTC and CA already decided upon. It was proven by the RTC that the land
originally belongs to the Quisimbings and the lands in controversy are accretion of lands. Since
Quisumbing own the property adjacent to the lands in controversy, the accretion of lands could
only benefit the Quisumbings. Also, SC confirmed fraud by its previous case ruling that the
petitioners are liable in Anti-Graft and Corrupt Practices Act in the issuance of the same free
patents and titles.