Case Digest (G.R. No. L-17652) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In 1958, petitioners Ignacio, Eulogia, Alfonso, Eulalia, and Sofia Grande, heirs of Patricia Angui, filed Civil Case No. 1171 in the Court of First Instance of Isabela to quiet title over about 1.9964 hectares of alluvial land formed along the northeastern bank of the Cagayan River adjoining their 3.5032-hectare parcel (Original Certificate of Title No. 2982, June 9, 1934) in barrio Ragan, municipality of Magsaysay, Isabela. They alleged that respondents Domingo and Esteban Calalung entered the alluvial tract without consent circa September 1948. Respondents countered that they had been in continuous, open, and adverse possession under claim of ownership since 1933 or 1934. On May 4, 1959, the trial court ruled for petitioners, holding that accretions belong to riparian owners (Art. 457, New Civil Code; Art. 366, Old Civil Code), are imprescriptible when part of registered land (Sec. 46, Act No. 496), and that respondents’ possession was under ten years. On September 14, 1960, t Case Digest (G.R. No. L-17652) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Parties
- Petitioners: Ignacio, Eulogia, Alfonso, Eulalia, and Sofia Grande, heirs of Patricia Angui, registered owners of Lot No. 1, Plan PSU-83342 (3.5032 ha) in barrio Ragan, Magsaysay (formerly Tumauini), Isabela, under Original Certificate of Title No. 2982 (June 9, 1934).
- Respondents: Domingo and Esteban Calalung, occupying without petitioners’ consent the accreted portion of petitioners’ riparian land.
- Formation of the Accretion
- Original survey (c. 1930) fixed the Cagayan River as the northeastern boundary; subsequent gradual alluvial deposit by 1958 added approximately 19,964 m² (1.9964 ha).
- Petitioners allege continuous possession of the accretion until September 1948, when respondents entered and claimed ownership.
- Procedural History
- Complaint (Jan. 25, 1958) in CFI Isabela: action to quiet title and recover possession of the 19,964 m² accretion; damages, attorney’s fees, and costs claimed.
- Answer (Feb. 18, 1958): respondents assert continuous, open, undisturbed possession since prior to 1933, under claim of ownership.
- Lower Courts’ Decisions
- CFI Isabela (May 4, 1959): ruled for petitioners, holding the accretion belonged to the registered owner by operation of Articles 366 (Old CC) and 457 (New CC); rejected prescription (possession since 1948,
- Court of Appeals (Sept. 14, 1960): reversed, finding (a) accretion not automatically protected by Torrens system beyond original certificate area; (b) respondents’ credible evidence of possession from 1933/34; (c) acquisitive prescription had run in their favor.
- Supreme Court Review (June 30, 1962)
- Affirmed CA decision: accreted land not registered unless separately declared; subject to prescription.
- CA’s factual findings on adverse possession under Act 190 conclusive and unreviewable.
Issues:
- Does an accretion to a Torrens-titled riparian parcel become automatically registered land, thereby imprescriptible?
- Did respondents acquire the accreted parcel by acquisitive prescription?
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)