The Supreme Court affirmed that land claimed through accretion, or gradual soil deposit, does not automatically become private property. The Court emphasized that claimants must prove the land was formed by gradual deposits from a river’s current, not by a receding sea. Without this proof and proper registration, the land remains part of the public domain. This ruling clarifies the requirements for claiming ownership of land formed by accretion, ensuring that only those who meet the specific conditions established by law can successfully assert their rights.

Shifting Sands: Unraveling Claims of Accretion Along the Aklan River

In this case, Josephine P. Delos Reyes and Julius C. Peralta, represented by their attorney-in-fact, J.F. Javier D. Peralta, sought to quiet title over parcels of land they claimed were formed by accretion. They argued that these lands, adjacent to their registered property, had gradually accumulated through the natural action of the Aklan River. The Municipality of Kalibo, Aklan, however, disputed this claim, asserting that the land was part of the public domain and intended to use it as a garbage dumpsite. The central legal question was whether the Peraltas had sufficiently established their right to the land through accretion, thereby warranting the quieting of title in their favor.

The Supreme Court addressed the conditions necessary to claim land through accretion, referencing Article 457 of the Civil Code of the Philippines, which states:

Art. 457. To the owners of lands adjoining the banks of rivers belong the accretion which they gradually receive from the effects of the current of the waters.

The Court emphasized that for accretion to be recognized, the deposit of soil must be gradual and imperceptible, made through the effects of the current of the water, and taking place on land adjacent to the banks of rivers. In this case, the Court found the Peraltas’ evidence lacking in several key aspects. First, they were not even the registered owners of the adjacent lot where the accretion was claimed. Second, even if they were Juanito’s rightful successors, they still did not register the subject increment under their names. Ownership of the original property does not automatically equate to ownership of the accretion. As the court stated in Reynante v. CA:

Registration under the Land Registration and Cadastral Act does not vest or give title to the land, but merely confirms and, thereafter, protects the title already possessed by the owner, making it imprescriptible by occupation of third parties. But to obtain this protection, the land must be placed under the operation of the registration laws, wherein certain judicial procedures have been provided.

The Court also noted that the character of the land itself was questionable. The person who was purportedly the first occupant of the area stated that the disputed land was the effect of the change of the shoreline of the Visayan Sea, and not through the gradual deposits of soil coming from the river or the sea. Moreover, the Officer-in-Charge of the Community Environment and Natural Resources Office of the Bureau of Lands found the subject area was predominantly composed of sand rather than soil. These factors suggested that the increase in land area was due to the recession of the sea, not the gradual deposit of soil from the river, thus negating the claim of accretion.

The Court highlighted the importance of evidence demonstrating the gradual and imperceptible deposit of soil. The testimony of one of the plaintiffs, Javier, indicated that the Visayan Sea was significantly farther from the land in question over time, suggesting a recession rather than accretion. This undercut the Peraltas’ claim that the land was formed by the river’s current. Furthermore, the DENR consistently classified the area as public land, being part of either the Visayan Sea or the Sooc Riverbed, and subject to tidal influence. The sheriff’s report also indicated that part of the area was reached by the tide.

The Supreme Court gave weight to the findings of the DENR, recognizing its expertise in environmental matters. In Summit One Condominium Corporation v. Pollution Adjudication Board and Environmental Management Bureau-National Capital Region, the Court stated:

administrative agencies, like the DENR, are in a better position to pass judgment on the same, and their findings of fact are generally accorded great respect, if not finality, by the courts. Such findings must be respected as long as they are supported by substantial evidence, even if such evidence is not overwhelming or even preponderant.

The Peraltas’ reliance on tax declarations was also deemed insufficient to prove ownership. The Court reiterated that tax declarations alone do not constitute proof of possession or ownership, especially without evidence of actual possession of the property. In Heirs of Oclarit v. CA, the Court clarified:

Any person who claims ownership by virtue of tax declarations must also prove that he has been in actual possession of the property. Thus, proof that the property involved had been declared for taxation purposes for a certain period of time, does not constitute proof of possession, nor is it proof of ownership, in the absence of the claimant’s actual possession of said property.

Considering the totality of the evidence, the Supreme Court concluded that the Peraltas failed to establish their legal or equitable title to the land in question. As such, their action for quieting of title could not prosper. The Court emphasized that in civil cases, the burden of proof rests on the plaintiff to demonstrate their claim with a preponderance of evidence. Since the Peraltas did not sufficiently prove that the land was formed by gradual accretion from the river and that they had a valid claim to the property, the Court upheld the CA’s decision declaring the land as part of the public domain.

FAQs

What was the key issue in this case?	The key issue was whether the Peraltas had sufficiently proven their claim of ownership over the land through accretion, entitling them to quiet title against the Municipality of Kalibo.
What is accretion in legal terms?	Accretion refers to the gradual and imperceptible addition of soil to the banks of rivers due to the natural action of the water current.
What are the requirements to claim land through accretion?	The requirements are that the deposit be gradual and imperceptible, made through the effects of the current of the water, and taking place on land adjacent to the banks of rivers.
Why did the Peraltas’ claim fail in this case?	The Peraltas’ claim failed because they did not adequately prove that the land was formed by gradual deposits from the river. Evidence suggested the land was formed by the receding sea, not accretion.
What role did the DENR’s findings play in the Court’s decision?	The DENR’s classification of the land as public domain, being part of either the Visayan Sea or the Sooc Riverbed, was given significant weight by the Court due to the agency’s expertise in environmental matters.
Are tax declarations sufficient to prove ownership of land?	No, tax declarations alone are not sufficient to prove ownership. Claimants must also demonstrate actual possession of the property.
What is the significance of registering land under the Torrens system?	Registration under the Torrens system confirms and protects the title already possessed by the owner, making it imprescriptible by occupation of third parties.
What is an action for quieting of title?	An action for quieting of title is a legal remedy to remove any cloud or doubt over the title to real property, ensuring the owner’s rights are secure and clear.
What is preponderance of evidence?	Preponderance of evidence means that the evidence presented by one party is more credible and convincing than the evidence presented by the opposing party.

This case underscores the importance of providing sufficient evidence to support claims of accretion. Landowners must demonstrate that the increase in land area was indeed the result of gradual and imperceptible deposits from a river, not other natural processes. This ruling also reinforces the principle that government agencies’ findings on land classification are given significant weight, and mere tax declarations are insufficient to establish ownership.

For inquiries regarding the application of this ruling to specific circumstances, please contact ASG Law through contact or via email at frontdesk@asglawpartners.com.

Disclaimer: This analysis is provided for informational purposes only and does not constitute legal advice. For specific legal guidance tailored to your situation, please consult with a qualified attorney.
Source: Josephine P. Delos Reyes and Julius C. Peralta v. Municipality of Kalibo, Aklan, G.R. No. 214587, February 26, 2018