In Heirs of Pacencia Racaza v. Spouses Florencio Abay-Abay, the Supreme Court reiterated that foreshore land, being part of the public domain, cannot be subject to private ownership. The Court emphasized that factual questions are beyond the scope of a Rule 45 petition and affirmed the lower courts’ findings, which favored the respondents’ long-standing possession over the petitioners’ claim based on a tax declaration. This ruling underscores the principle that claims of ownership over foreshore land can only be pursued by the Republic of the Philippines, not by private individuals.

Ancestral Claim or Public Domain? The Battle Over Foreshore Land in Ubay, Bohol

The case revolves around a dispute over a parcel of land in Poblacion Ubay, Bohol, where the Heirs of Pacencia Racaza claimed co-ownership based on a tax declaration issued in their predecessor’s name. The Spouses Abay-Abay, on the other hand, asserted their ownership through a Deed of Absolute Sale from the estate of Emilia Garces, along with their continuous possession of the land since 1917. This conflict began when the Abay-Abay spouses filed a complaint for quieting of title against several defendants, including Alexander Miel, the husband of one of the Racaza heirs. The legal question at the heart of the matter was whether the disputed property was private land subject to ownership by either party or foreshore land belonging to the public domain.

The petitioners, the Heirs of Racaza, sought to introduce new evidence in their petition before the Supreme Court, specifically a certification from the Community Environment and Natural Resources Office (CENRO) and a cadastral map, to prove that the land in question was actually foreshore land. This argument was crucial because, under Philippine law, foreshore land is part of the public domain and cannot be privately owned. The Supreme Court, however, denied the petition, citing the well-established rule that petitions under Rule 45 of the Rules of Court can only raise questions of law, not questions of fact. The Court emphasized that it is not its function to re-evaluate evidence already considered by the lower courts.

Building on this principle, the Court also rejected the petitioners’ attempt to introduce “newly discovered evidence” at this late stage of the proceedings. The requisites for admitting newly discovered evidence are stringent, requiring that the evidence was discovered after trial, could not have been discovered with reasonable diligence during trial, and is material enough to potentially change the outcome of the case. In this instance, the Court found that the CENRO certification and cadastral map could have been obtained and presented during the trial in the lower courts. Therefore, they did not meet the criteria for newly discovered evidence.

Moreover, the Supreme Court highlighted the implications of the petitioners’ argument that the land was foreshore land. Even if the evidence were admitted, it would not support the petitioners’ claim of ownership. As the Court pointed out, foreshore land belongs to the public domain and cannot be privately owned. Citing Republic of the Philippines v. CA, the Court reiterated that land invaded by the sea becomes foreshore land and passes to the public domain. Consequently, if the land was indeed foreshore land, the proper party to assert a claim would be the Republic of the Philippines, not the private petitioners.

Furthermore, the Court underscored the significance of the prior legal proceedings in Civil Case No. 3920, where the Spouses Abay-Abay had successfully sued to quiet their title against Alexander Miel. The fact that Angeles Racaza Miel, one of the heirs, was aware of the case but did not intervene or inform her co-heirs was a critical factor in the lower courts’ decisions. This inaction was interpreted as an indication of the weakness of the Racaza heirs’ claim. Moreover, Angeles Racaza Miel’s promise to vacate the property in connection with the earlier case further undermined her claim of ownership.

In essence, the Supreme Court’s decision hinged on procedural rules and the principle that foreshore land is inalienable. The Court declined to delve into factual questions about the nature of the land and instead focused on the petitioners’ failure to comply with the requirements for a Rule 45 petition and the introduction of new evidence. This decision reaffirms the importance of raising factual issues and presenting evidence at the appropriate stage of legal proceedings. It also underscores the limitations on private claims to land that is part of the public domain.

FAQs

What was the key issue in this case?	The key issue was whether the disputed property was private land subject to ownership by the petitioners or respondents, or foreshore land belonging to the public domain, and whether the Supreme Court could consider new evidence at this stage.
What is foreshore land?	Foreshore land is the area between the high and low watermarks that is alternately wet and dry according to the tides. Under Philippine law, foreshore land is part of the public domain and cannot be privately owned.
Why did the Supreme Court deny the petition?	The Supreme Court denied the petition because it raised questions of fact, which are beyond the scope of a Rule 45 petition, and because the petitioners failed to present newly discovered evidence that met the legal requirements for admissibility.
What is a Rule 45 petition?	A Rule 45 petition is a petition for review on certiorari filed with the Supreme Court, which can only raise questions of law, not questions of fact.
What were the requirements for newly discovered evidence in this case?	The requirements are: (a) the evidence was discovered after trial; (b) such evidence could not have been discovered and produced at the trial with reasonable diligence; and (c) it is material, not merely cumulative, corroborative or impeaching, and is of such weight that, if admitted, will probably change the judgment.
Who can claim ownership of foreshore land?	Because it’s part of the public domain, only the Republic of the Philippines can assert rights over foreshore land, not private individuals.
What was the significance of the prior legal proceedings?	The prior legal proceedings in Civil Case No. 3920, where the Spouses Abay-Abay successfully sued to quiet their title, were significant because they undermined the Racaza heirs’ claim of ownership due to their inaction and implied admission of the Abay-Abay’s rights.
What is the practical implication of this ruling?	This ruling reinforces the principle that claims of ownership over foreshore land will not be recognized by the courts and that the Republic of the Philippines is the proper party to assert such claims.

This case serves as a reminder of the importance of understanding property rights and the limitations on private ownership, particularly when it comes to land that is part of the public domain. It also highlights the importance of raising factual issues and presenting evidence at the appropriate stage of legal proceedings to protect one’s interests.

For inquiries regarding the application of this ruling to specific circumstances, please contact ASG Law through contact or via email at frontdesk@asglawpartners.com.

Disclaimer: This analysis is provided for informational purposes only and does not constitute legal advice. For specific legal guidance tailored to your situation, please consult with a qualified attorney.
Source: Heirs of Pacencia Racaza v. Spouses Florencio Abay-Abay, G.R. No. 198402, June 13, 2012