Republic vs. Vda. de Castillo

The Court held that a land registration decree is void and cannot constitute res judicata if the land adjudicated is part of the public domain, such as a lake bed or shore land, which is outside the commerce of man and not susceptible to private appropriation. Because the subject lots were proven to be portions of Taal Lake, the registration court had no jurisdiction to adjudicate them, rendering its decision null and void.

Modesto Castillo secured the registration of two parcels of land (Lots 1 and 2, Psu-119166) in Banadero, Tanauan, Batangas, in 1951, obtaining Original Certificate of Title No. 0-665. After his death, the properties were subdivided among his heirs, the private respondents, resulting in the issuance of new transfer certificates of title. The Republic of the Philippines later filed an action for annulment of these titles and reversion of the lots to the State, alleging that the lands had always formed part of Taal Lake and were therefore public dominion, not subject to private ownership.

• In 1951, Modesto Castillo obtained a decree of registration and Original Certificate of Title No. 0-665 for Lots 1 and 2 in Banadero, Tanauan, Batangas.
• After Castillo's death, his heirs (private respondents) subdivided the property, leading to the issuance of new transfer certificates of title.
• The Republic alleged that Lots 1 and 2 had always formed part of Taal Lake, were washed and inundated by its waters, and were therefore public dominion not subject to private ownership.
• Government evidence, including survey plans and witness testimony, established that the 1923 cadastral survey showed the lots as foreshore land of Taal Lake. A 1948 survey plan annotated the lots as "claimed by the Republic of the Philippines." A 1962 relocation survey found monuments under water.
• Witnesses testified that the area was under water during the rainy season and that occupants (not the Castillos) had filled the land with shells, sand, and duck waste to make it habitable.
• Private respondents claimed continuous, adverse possession by the Castillo family for over 76 years, arguing the inundation was accidental due to a 1911 volcanic eruption and did not divest their ownership under the Law of Waters.

• The Republic maintained that the registration court in 1951 lacked jurisdiction to adjudicate Lots 1 and 2 as private property because they were portions of Taal Lake, which is property of public dominion and outside the commerce of man.
• It argued that since the land was public, the registration decree was void and could not operate as res judicata to bar the reversion action.
• The Republic contended that its evidence proved the lots were shorelands of Taal Lake, not private land subject to accretion or prescription.

• The private respondents argued that the government's action was barred by the prior final judgment of the registration court, invoking res judicata.
• They claimed the action had prescribed and that the government was estopped from questioning their ownership after the title had been issued.
• They asserted that the lands were in the possession of the Castillo family for over 76 years, and that any inundation was accidental, not altering the private character of the property under Article 778 of the Law of Waters.

• Procedural Issues: N/A
• Substantive Issues: Whether the decision of the Land Registration Court in 1951 constitutes res judicata and bars the State's action for reversion of the lots to the public domain.

• Procedural: N/A
• Substantive: The Supreme Court ruled that the land registration decree did not constitute res judicata. The Court found that the subject lots were portions of Taal Lake, a property of public dominion. Consequently, the registration court had no jurisdiction to adjudicate them as private property. A judgment rendered without jurisdiction is void and cannot be the basis of res judicata. The Court reversed the Intermediate Appellate Court and reinstated the trial court's decision ordering the cancellation of the titles and reversion of the lots to the State.

• Res Judicata — The doctrine bars a subsequent action between the same parties on the same subject matter and cause of action after a final judgment on the merits by a court of competent jurisdiction. The Court held that the doctrine did not apply because the land registration court lacked jurisdiction over the subject matter (public land), rendering its judgment void ab initio.
• Inalienability of Public Dominion — Lands of the public domain, such as lakes, their beds, and shores, are outside the commerce of man and cannot be the subject of private appropriation or registration. The Court applied this principle to declare the registration of portions of Taal Lake null and void.

• "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." — This passage underscores the fundamental principle that public dominion lands cannot be privately owned through registration.

• Republic v. Ayala y Cia, 14 SCRA 259 (1965) — Cited for the principle that foreshore lands are not registrable and inclusion in a title does not confer ownership.
• Dizon, et al. v. Bayona, et al., 98 Phil. 943 — Referenced to support the non-registrability of foreshore lands.
• Cuevas v. Pineda, 143 SCRA 674 (1988) — Cited for the rule that mere possession does not divest land of its public character.
• Gov't. v. Colegio de San Jose, 53 Phil. 423 — Mentioned to distinguish accretions on lake banks (which belong to the riparian owner) from those on sea banks (which belong to the State).

• Article 420, Civil Code — Defines property of public dominion, including lakes and their beds, intended for public use.
• Article 502, paragraph 4, Civil Code — Classifies lakes and their beds as property of the State.
• Article 778, Law of Waters (Old) — Invoked by respondents regarding accidental inundation; the Court's ruling implicitly found it inapplicable as the land was inherently part of the lake.