Case Summary (G.R. No. L-17652)
Chronology and Factual Background
• 1930–1931: Original lot surveyed; boundary fixed at the Cagayan River.
• 1933–1941: Gradual river-borne accretion begins; by 1940–1941, approximately one hectare added.
• September 1948: Respondents enter and declare the accretion under Tax Declaration No. 257.
• January 25, 1958: Petitioners file Civil Case No. 1171 for quiet title and recovery of possession, plus damages, attorney’s fees, and costs.
Decision of the Court of First Instance
On May 4, 1959, the trial court awarded title to petitioners over the accretion, relying on:
- Civil Code natural-accession rules (Old Code art. 366; New Code art. 457), vesting riparian accretions in the registered owner.
- Torrens-system imprescriptibility (Act No. 496, sec. 46), preventing adverse prescription against registered land.
- Insufficient adverse-possession period (respondents’ occupation from 1948 to January 1958 fell short of the 10-year requirement under New Civil Code arts. 1134 and 1138).
Decision of the Court of Appeals
On September 14, 1960, the appellate court reversed, holding that:
• Accretions, while owned by the riparian proprietor under the Civil Code, do not ipso facto become registered land protected by the Land Registration Act beyond the area described in the certificate.
• Registration protects only the land specifically described; added alluvial formations remain unregistered and thus subject to prescription.
• Respondents proved by credible witnesses (including municipal officials and boundary owners) that they had been in continuous, open, and adverse possession since 1933–1934—supported by tax declarations in 1946 and 1948—well beyond ten years prior to the 1958 filing.
Issues on Accretion and Registration
The Supreme Court agreed that ownership by accession under Civil Code provisions is distinct from registration under the Torrens system. It emphasized:
• Torrens registration confirms and protects titles existing at registration; it does not automatically extend to subsequent accretions.
• To gain imprescriptibility, the new land must undergo separate registration procedures.
• Petitioners neve
Case Syllabus (G.R. No. L-17652)
Procedural Posture
- Petitioners Ignacio, Eulogia, Alfonso, Eulalia, and Sofia Grande appealed the decision of the Court of Appeals (CA-G.R. No. 25169-R) which reversed the Court of First Instance of Isabela’s ruling and dismissed their action to quiet title and recover possession of a newly formed alluvial parcel.
- The Court of First Instance (Civil Case No. 1171) had originally adjudged the accreted land to petitioners, ordered respondents to vacate and deliver possession, and awarded damages and costs.
- Respondents Domingo and Esteban Calalung appealed to the Court of Appeals, which rendered decision on September 14, 1960, holding that respondents acquired the parcel by prescription.
- Petitioners sought review by the Supreme Court of the Court of Appeals’ decision.
Facts
- Petitioners are registered owners by inheritance of a 3.5032-hectare parcel in Barrio Ragan, Magsaysay, Isabela, under Original Certificate of Title No. 2982 (issued June 9, 1934).
- The registered land’s northeastern boundary is the navigable Cagayan River.
- From circa 1930 onward, gradual accretion from the river added approximately 1.9964 hectares by 1958.
- Petitioners alleged peaceful possession of the accretion until September 1948, when respondents entered under claim of ownership.
- Respondents claimed continuous, open, undisturbed possession of the accretion since before 1933.
- Petitioners filed suit on January 25, 1958, seeking quiet title to the accretion, recovery of possession, damages for fruits, attorney’s fees, and costs.
- Respondents answered on February 18, 1958, alleging they had been in possession since before 1933.
Issue
- Whether respondents, having occupied the alluvial portion of petitioners’ registered land without challenge, acquired ownership of that alluvial parcel by acquisitive prescription.
Court of First Instance Ruling
- Found that the alluvion formed after petitioners’