- Petitioner
- Josephine P. Delos Reyes
- Respondent
- Municipality of Kalibo
- Citation
- G.R. No. 214587
- Court
- Supreme Court
- Division
- Second Division
- Ponente
- Peralta, J.
- Decided
- February 26, 2018
Summary
The Supreme Court affirmed that contested parcels of land in Kalibo, Aklan belong to the public domain rather than to the Peralta heirs. The petitioners claimed ownership through accretion under Article 457 of the Civil Code, tracing their title from a 1955 quitclaim by tenant Ambrocio Ignacio. However, the Court found that petitioners lacked legal or equitable title as the quitclaim was invalid due to Ignacio's lack of ownership rights. The land was characterized as swampy area formed by sea recession rather than gradual soil deposits required for accretion. The DENR's expertise in classifying the area as public domain was given deference. The decision reinforces that accretion must meet specific requirements under Civil Code Article 457 and that tax declarations alone cannot establish ownership without actual possession and valid title.