Title
Grande vs. Court of Appeals
Case
G.R. No. L-17652
Decision Date
Jun 30, 1962
Petitioners inherited land bordering Cagayan River; accretion formed over time. Respondents claimed ownership via prescription. Court ruled accretion not automatically registered, granting ownership to respondents due to continuous, adverse possession since 1933/34.
A

Case Digest (G.R. No. L-17652)

Facts:

Petitioners Ignacio Grande, et al. owned a parcel of land of 3.5032 hectares in barrio Ragan, municipality of Magsaysay (formerly Tumauini), province of Isabela, as heirs of Patricia Angui, the title to which stood in the names of Isidro Angui and Ana Lopez as shown by Original Certificate of Title No. 2982, issued June 9, 1934, Lot No. 1, Plan PSU-83342, whose northeastern boundary at the time of survey was the Cagayan River. Since the 1930 survey a gradual accretion took place along the northeastern side so that by 1958 an alluvial deposit of 19,964 square meters had been added to the registered area and the riverbank had receded about 105 meters. On January 25, 1958 petitioners filed in the Court of First Instance of Isabela Civil Case No. 1171 to quiet title to and recover possession of the accretion, alleging prior peaceful possession until September 1948 when respondents Domingo Calalung and Esteban Calalung entered and occupied the alluvial land; respondents answered on February 18, 1958 denying petitioners’ claim and asserting continuous, open, and undisturbed possession since prior to 1933. After trial the Court of First Instance rendered judgment on May 4, 1959 awarding the accretion to petitioners, ordering respondents to vacate and deliver possession, and awarding petitioners P250.00 as damages and costs, the trial court reasoning that the accretion belonged to the registered lot under Art. 457, New Civil Code (formerly Art. 366, Old Civil Code) and that, as accretion to registered land, it was within the protection of Section 46 of Act No. 496 against acquisition by prescription. Respondents appealed and the Court of Appeals on September 14, 1960 reversed, holding that an accretion does not ipso jure become registered land and that respondents had acquired the alluvion by prescription after adverse possession since 1933–1934; petitioners then sought review before the Supreme Court.

Issues:

Did respondents acquire ownership of the alluvial increment by acquisitive prescription? Did accretion to land already covered by a Torrens title ipso jure become registered land and therefore immune from acquisition by prescription under Section 46 of Act No. 496?

Ruling:

  • (Subscriber-Only)

Ratio:

  • (Subscriber-Only)

Doctrine:

  • (Subscriber-Only)

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