Case Summary (G.R. No. 161081)
Key Dates
• March 7, 1997 – Initial registration application by Arcadio Ivan.
• May 21, 1998 – Amendment to include Arcadio Jr.
• May 10, 2000 – RTC grants registration.
• May 27, 2003 – CA affirms RTC.
• October 20, 2003 – CA denies motion for reconsideration.
• November 12, 2012 – Supreme Court decision.
Applicable Law
• 1987 Philippine Constitution (decision after 1990).
• Civil Code of the Philippines: Articles 457, 461, 502.
• Presidential Decree No. 1529 (Property Registration Decree), Section 14(1).
Procedural History
Respondents filed for Torrens registration on the ground of more than ten years’ adverse possession, later amending to assert co-ownership. The City of Parañaque opposed, citing flood-control easement and alleging the land was a dried river bed, not accretion. The RTC granted registration under Article 457 (accretion), and the CA affirmed. The Republic appealed to the Supreme Court.
Issues on Appeal
- Whether Article 457 (accretion) applies when the river bed dried up.
- Whether respondents could claim the property under acquisitive prescription (Section 14(1) PD 1529).
- Whether failure to present certification of alienability and disposability is fatal.
- Sufficiency of evidence of continuous, open, public, adverse possession for over 30 years.
Accretion Claim Under Article 457
Article 457 vests accreted land in riparian owners only when soil is deposited gradually and imperceptibly by river currents. Respondents’ own evidence established that Lot 4998-B resulted from the river drying up, not from accretion. The substantial area (1,045 sqm) could not plausibly have formed by gradual deposition within 20–30 years. Both RTC and CA erred in treating the dried river bed as accretion. Under Article 502, rivers and their beds remain public dominion; a dried-up bed likewise belongs to the State absent a specific law vesting title elsewhere.
Acquisitive Prescription and Public Domain Land
Section 14(1) PD 1529 allows registration of imperfect title only on alienable and disposable public lands, subject to open, continuous, exclusive, notorious possession since June 12, 1945. Even assuming respondents possessed the land for over 30 years, (i) payment of realty taxes and survey alone do not establish the requisite possession; (ii) the land remained part of the inalienable public domain because no positive government act (proclamation, executive order, administrative classification, or certified land classification) declared it alienable and disposable.
Requirement of Alienability and Disposability
Mere notation on a survey plan that the area falls within a map classified as alienable/disposable by the Bureau of Forest Development is not a positive act o
Case Syllabus (G.R. No. 161081)
Antecedents
- Arcadio Ivan A. Santos III and Arcadio C. Santos, Jr. applied for registration of Lot 4998-B in Parañaque City on March 7, 1997, claiming continuous, adverse possession for over 30 years.
- The property (1,045 m²) was bounded northeast by Lot 4079 (Arcadio Jr.), southeast by the Parañaque River, southwest by an abandoned road, and northwest by Lot 4998-A (Arcadio Ivan).
- On May 21, 1998, Arcadio Ivan amended the application to include Arcadio Jr. as co-applicant, alleging the land was formed by accretion.
- The City of Parañaque opposed, arguing the land lay within a 20-meter easement, was needed for flood control, and was a dried-up riverbed, not accretion.
Procedural History
- RTC, Branch 118, Parañaque City (May 10, 2000): Declared the applicants “true and absolute owners” of Lot 4998-B under Article 457, New Civil Code, ordering registration.
- Republic of the Philippines (Office of the Solicitor General) appealed to the Court of Appeals.
- CA, Fourth Division (May 27, 2003): Affirmed the RTC decision in toto. Motion for reconsideration denied (Oct. 20, 2003).
- Republic elevated the case to the Supreme Court (G.R. No. 160453).
Issues
- Whether Article 457 (accretion to riparian lands) applies when