Primary Holding

The dried-up portion of Estero Calubcub is public land, not private property of the riparian owners, because its drying up was caused by human intervention and not a natural change in the course of the waters.

Background

Rosendo del Rosario and his daughters claimed ownership of a dried-up estero portion adjacent to their titled land, asserting riparian rights. Mario Ronquillo occupied this portion and claimed it was public land. The Director of Lands and Development Bank of the Philippines were later impleaded as respondents.

Facts

• 1. Rosendo del Rosario owned titled land (Lot 34) adjacent to Estero Calubcub.
• 2. Estero Calubcub dried up around 1960 due to garbage dumping.
• 3. Ronquillo occupied the dried-up estero portion since 1945 and built a house there.
• 4. Del Rosarios claimed ownership of the dried-up estero as riparian owners under Article 370 of the old Civil Code.
• 5. Both parties filed sales applications for the dried-up estero with the Bureau of Lands.
• 6. The Manila City Engineer's Office objected to these applications as the land was needed for drainage purposes.

Arguments of the Petitioners

• 1. Ronquillo argued that the Court of Appeals erred in applying Article 370 of the old Civil Code because the estero dried up due to human intervention, not natural causes.
• 2. He contended that the dried-up estero is public land under the disposition of the Director of Lands, and not subject to private ownership.
• 3. He claimed the Court of Appeals wrongly relied on Pinzon vs. Rama, which was factually different.

Arguments of the Respondents

• 1. Del Rosarios argued that as riparian owners, they were entitled to the dried-up estero bed under Article 370 of the old Civil Code.
• 2. They asserted that the Court of Appeals correctly affirmed the trial court's decision recognizing their ownership.

Issues

• 1. Whether the dried-up portion of Estero Calubcub is private property of the Del Rosarios as riparian owners.
• 2. Whether Article 370 of the old Civil Code applies to the case, considering the cause of the estero's drying up.
• 3. Whether the dried-up estero is public land.

Ruling

• 1. The Supreme Court ruled that Article 370 of the old Civil Code is not applicable because the drying up of Estero Calubcub was not due to a natural change in the course of the waters, but due to the dumping of garbage by residents.
• 2. The Court found that the relocation plan and Florencia del Rosario’s testimony indicated that the drying up was caused by garbage, not natural processes.
• 3. Since Article 370 requires a natural change in the water course for riparian ownership, it does not apply to this case.
• 4. The Court concluded that the dried-up estero remains public land, not susceptible to private ownership, and is under the administration of the Bureau of Lands, especially given the City Engineer's need for it for drainage.

Doctrines

• 1. Riparian Ownership (Article 370, Old Civil Code): This doctrine states that beds of rivers abandoned due to natural changes in the course of waters belong to riparian owners. The Court clarified this doctrine is inapplicable when the change is not natural.
• 2. Public Domain: Land of the public domain cannot be privately owned unless there is express government grant. The dried-up estero, not being naturally abandoned riverbed, remains part of the public domain.
• 3. Estoppel: By filing sales applications for the dried-up estero, both Ronquillo and Del Rosarios implicitly admitted that the land was public, and are thus estopped from claiming private ownership later.

Key Excerpts

• 1. "(E)ven assuming for the sake of argument that said estero did not change its course but merely dried up or disappeared, said dried-up estero would still belong to the riparian owner." - Court of Appeals' cited ruling in Pinzon vs. Rama, which the Supreme Court distinguished.
• 2. "Art. 370. The beds of rivers, which are abandoned because of a natural change in the course of the waters, belong to the owners of the riparian lands throughout the respective length of each." - Article 370 of the Old Civil Code.
• 3. "It has been the dumping place of the whole neighborhood. There is no street, they dumped all the garbage there. It is the dumping place of the whole community, sir." - Testimony of Florencia del Rosario, highlighting human intervention.

Precedents Cited

• 1. Pinzon vs. Rama (CA-G.R. No. 8389, Jan. 8, 1943): Cited by the Court of Appeals to support riparian ownership even if the estero merely dried up. The Supreme Court distinguished this case, finding different factual circumstances in Ronquillo.
• 2. Fabian vs. Paculan (CA-G.R. Nos. 21062-63-64-R, Jan. 25, 1962): Cited by the Court of Appeals in its decision, related to abandoned riverbeds belonging to riparian owners when naturally changed.
• 3. Director of Lands vs. Santiago (160 SCRA 186, 194): Cited by the Director of Lands regarding estoppel due to sales applications, reinforcing the idea that applicants acknowledged public land status.
• 4. Bunag vs. Court of Appeals, et al., 158 SCRA 299 (1988): Cited for the exceptions to the conclusivity of the Court of Appeals’ factual findings.
• 5. Republic vs. Court of Appeals, et al., 132 SCRA 214 (1984): Cited regarding the rule that alluvion rules do not apply to man-made accretions or artificial drainage systems.

Statutory and Constitutional Provisions

• 1. Article 370 of the Old Civil Code: Regarding ownership of beds of rivers abandoned due to natural changes in the course of waters.
• 2. Article 502 (No. 1) of the New Civil Code: Cited by the Director of Lands, likely concerning properties of public dominion, although not directly discussed in detail in the excerpt provided beyond its mention in the Director's comment.