G.R. No. 224973 - Lefebre vs. A Brown Co., Inc.

Over 50 years ago, petitioner Jose Reynante was taken as a tenant by the late Don Cosme Carlos over a fishpond located in Barrio Liputan, Meycauayan, Bulacan.
The fishpond, covering an area of approximately 188.711 square meters, was evidenced by Transfer Certificate of Title No. 25618 and registered in the Land Registry of Bulacan.

During his tenancy, petitioner constructed a nipa hut on the property where he and his family resided.
He planted nipa palms (locally referred to as sasahan) on two lots (Lots 1 and 2) with areas of 5.096 square meters and 6.011 square meters respectively, located between the fishpond covered by the title and the Liputan (formerly Meycauayan) River.
The petitioner harvested and sold the nipa palms without interference or objection from Don Cosme Carlos.

Following the death of Don Cosme Carlos, his heirs, who became the private respondents’ predecessors-in-interest, executed a written agreement entitled "SINUMPAANG SALAYSAY NG PAGSASAULI NG KARAPATAN" dated November 29, 1984.
Under this agreement, petitioner surrendered the fishpond and all corresponding tenant rights as a caretaker ("bantay-kasama at tagapamahala") in exchange for P200,000.00.
Notably, this surrender did not clearly include the land (Lots 1 and 2) where the petitioner’s nipa hut was built and the nipa palms were planted.

Petitioner continued to reside in the constructed nipa hut on Lots 1 and 2 and maintained possession of the nipa palms he had planted there.
On February 17, 1988, the heirs (private respondents) formally demanded that petitioner vacate the portion containing Lots 1 and 2, contending that he had already been indemnified for surrendering his rights over the fishpond.
Petitioner refused to vacate, prompting private respondents to file a complaint for forcible entry with a preliminary mandatory injunction on April 22, 1988.
The Municipal Trial Court of Meycauayan, Branch I, initially dismissed the complaint, finding in favor of petitioner based on his demonstrated prior possession.
Private respondents appealed to the Regional Trial Court, which on August 8, 1989, reversed the trial court’s decision and ordered petitioner to restore possession of Lots 1 and 2 along with the nipa palms.
The Court of Appeals subsequently affirmed the Regional Trial Court’s ruling on February 28, 1990, denying petitioner’s motion for a restraining order and later dismissing his motion for reconsideration on November 5, 1990.
Petitioner's review on certiorari led to the eventual intervention by the Supreme Court in this case.

Whether petitioner or the private respondents can establish priority in physical possession of Lots 1 and 2.
Whether petitioner’s longstanding possession over these lots for more than 50 years sufficiently establishes his priority despite any purported surrender of rights over the fishpond.

Whether the written agreement executed on November 29, 1984, which involved the surrender of rights by the petitioner, specifically included the land on which the nipa hut and nipa palms were located.
The legal implications of the agreement in distinguishing the fishpond from the adjacent Lots 1 and 2.

Whether the disputed Lots 1 and 2, not being covered by the original TCT and possibly formed by alluvial deposition (accretion), automatically belong to the private respondents under Article 457 of the New Civil Code.
The impact of the failure to register the accreted lands on private respondents’ claim, considering the petitioner’s prolonged possession and potential acquisition through prescription.