**Desamparado Vda. de Nazareno and Leticia Nazareno Tapia vs. The Court of Appeals et al.: A Philippine Legal Battle Over Public Land Classification and Administrative Remedies**
### Facts:
The case involves a parcel of land situated in Cagayan de Oro City, Philippines, which became the subject of dispute after being transformed by deposits of sawdust and other materials. Antonio Nazareno, the predecessor-in-interest of the petitioners (Desamparado Vda. de Nazareno and Leticia Nazareno Tapia), initially leased the land to the respondents (Jose Salasalan and Leo Rabaya) in 1979. However, after the lessees stopped paying rent in 1982, eviction proceedings were initiated, leading to multiple legal actions across various courts, all resulting in favor of the eviction.
Antonio Nazareno sought to perfect his title over the land by having Bureau of Lands approve a survey plan. This move was protested by the respondents at the Bureau, leading to an investigation that recommended the cancellation of Nazareno’s survey plan and the filing of public land applications by the respondents. The Bureau of Lands, through a series of decisions, eventually ordered the amendment of the survey plan to exclude the areas occupied by the respondents.
The petitioners filed a case at the RTC to annul the Bureau’s decisions due to non-exhaustion of administrative remedies, which was dismissed. The Court of Appeals affirmed the RTC’s dismissal, prompting the petition to the Supreme Court on the grounds of the land’s classification and the exhaustion of administrative remedies.
### Issues:
1. Whether the subject land is private or public land.
2. Whether petitioners exhausted administrative remedies.
### Court’s Decision:
The Supreme Court determined the land to be public, given the man-made alterations did not meet the natural accretion criteria under Article 457 of the Civil Code. It concluded that the Bureau of Lands and the Department of Agriculture and Natural Resources hold jurisdiction over the land. Moreover, the Court recognized that administrative remedies were indeed exhausted when the motion for reconsideration was made, effectively dismissing the petition for lacking merit.
### Doctrine:
The case reiterates the doctrine that for land to be considered for riparian rights under Article 457 of the Civil Code, the accretion must be gradual, imperceptible, and the result of the action of the waters of the river. It also affirms the principle that findings of administrative agencies, which specialize in specific fields, are generally accorded not only respect but even finality, especially when affirmed by the Court of Appeals.
### Class Notes:
– Riparian Rights: Accretions must be natural, gradual, and imperceptible.
– Administrative Remedies: Must be exhausted before recourse to courts, unless exceptional circumstances exist.
– Public Land Classification: Land altered through human intervention does not meet the criteria for private land accretion.
### Historical Background:
This case underscores the complex nature of land disputes in the Philippines, particularly involving land classification between public and private ownership, and the procedural nuances of exhausting administrative remedies before judicial intervention. It highlights the balance between respecting administrative agency findings and ensuring that aggrieved parties have recourse to the courts when necessary.
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