G.R. No. 160453 - Republic vs. Santos III

On March 7, 1997, Arcadio Ivan A. Santos III filed an application in the RTC of Parañaque City to register Lot 4998-B (1,045 sqm), located in Barangay San Dionisio, Parañaque City, bounded: northeast by Lot 4079 (Arcadio C. Santos Jr.), southeast by the Parañaque River, southwest by an abandoned road, and northwest by Lot 4998-A (Arcadio Ivan).
On May 21, 1998, the application was amended to include Arcadio C. Santos Jr. as co-applicant. They alleged the lot was formed by accretion and that they had open, notorious, continuous and adverse possession for over 30 years.

The City of Parañaque opposed, citing the lot’s need for flood control, its inclusion in the 20-m legal easement, and that it was a dried-up river bed—not accretion.
On May 10, 2000, the RTC granted registration in favor of the Santoses.
The Republic, through the OSG, appealed. On May 27, 2003, the CA affirmed the RTC. A motion for reconsideration was denied on October 20, 2003.

Whether the lot, being a dried-up river bed, qualifies as accretion under Article 457 of the Civil Code.
Whether the lot, if deemed previously part of the river, may be registered under Article 461 of the Civil Code.
Whether the failure to formally offer an official certification of alienability and disposability is fatal to the application.
Whether respondents proved open, continuous, exclusive and adverse possession for more than 30 years.