Spouses Crispin Galang v. Spouses Conrado S. Reyes

Summary

This property dispute involved competing ownership claims over land allegedly formerly occupied by Marigman Creek. The Reyeses claimed the creek naturally changed course in 1980, entitling them to the abandoned creek bed under Article 461 of the Civil Code. The Galangs held a free patent title (OCT No. P-928) from DENR over the same land. The RTC dismissed the case finding no fraud evidence. The CA reversed, accepting the creek bed theory. The Supreme Court ultimately reversed the CA, ruling that the Reyeses failed to prove by clear and convincing evidence the natural course change of the creek, the exact old and new courses, or any fraud in the patent issuance. The Court upheld the validity of the Galangs' free patent title, emphasizing that fraud allegations require clear and convincing proof, not mere preponderance of evidence, particularly when challenging a presumptively valid Torrens title.