Title
Republic vs. Court of Appeals
Case
G.R. No. L-61647
Decision Date
Oct 12, 1984
Private respondents claimed ownership of river-adjacent lots as natural accretions; Supreme Court ruled the accretion was man-made, declaring the land public domain and ordering restoration.

Case Digest (G.R. No. 97995)
Expanded Legal Reasoning Model

Facts:

  • Parties and Property
    • Private respondents Benjamin, Azucena, Marina and Mario Tancinco owned a 12-hectare fishpond covered by TCT No. T-89709, situated in Barrio Ubihan, Meycauayan, Bulacan, along Meycauayan and Bocaue rivers.
    • On June 24, 1973, they applied to register three adjacent parcels (Lots 1, 2 and 3 of Plan PSU-131892) totaling 41,375 sq.m. as accretions to their fishpond.
  • Procedural History
    • April 5, 1974: Assistant Provincial Fiscal filed opposition on behalf of the Bureau of Lands.
    • March 6–7, 1975: Private respondents withdrew Lot 3 from the application; trial proceeded on Lots 1 and 2 only.
    • June 26, 1976: CFI of Bulacan granted registration, finding Lots 1 & 2 natural accretions to TCT No. T-89709.
    • July 30, 1976: Republic of the Philippines (Director of Lands) appealed to the Court of Appeals.
    • August 19, 1982: CA affirmed the lower court decision in toto.
    • October 12, 1984: Supreme Court granted certiorari to review whether the additions were natural accretions or artificial reclamations and whether the lots were registrable.

Issues:

  • Nature of the Additions
    • Whether Lots 1 & 2 arose by natural, gradual and imperceptible river accretion under Civil Code Article 457.
    • Whether the accretion was man-made (dike extension/reclamation) and thus excluded from Article 457.
  • Registrability and Public Domain
    • Whether portions of the riverbed are part of the public domain and non-registrable under Land Registration Act.
    • Whether the trial court and CA committed grave abuse by misapprehending facts and ignoring evidence of artificial reclamation.

Ruling:

  • (Subscriber-Only)

Ratio:

  • (Subscriber-Only)

Doctrine:

  • (Subscriber-Only)

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