Republic of the Philippines v. Amanda Lat Vda. de Castillo

Summary

The Supreme Court ruled in favor of the Republic of the Philippines in this land registration dispute involving Lots 1 and 2 in Tanauan, Batangas. Originally registered in 1951 to Modesto Castillo and later subdivided among his heirs, the government sought to annul the titles claiming the lands were foreshore/lakeshore areas of Taal Lake belonging to public domain. Through extensive survey evidence and witness testimonies, the Court established that during the 1923 cadastral survey, these lots were part of Taal Lake's shoreline and remained under water, especially during rainy seasons. The Court emphasized that shores are public domain properties under Article 420 of the Civil Code and cannot be subject to private registration. Despite respondents' claims of long possession, the Court held that mere possession cannot divest land of its public character. The decision reinforces the inalienability of public domain lands and the State's sovereign authority over foreshore areas.