G.R. No. L-17652; June 30, 1962
IGNACIO GRANDE, ET AL., petitioners, vs. HON. COURT OF APPEALS, DOMINGO CALALUNG, and ESTEBAN CALALUNG, respondents.

FACTS

Petitioners are the registered owners of a parcel of land bordering the Cagayan River, as evidenced by Original Certificate of Title No. 2982 issued in 1934. Through gradual accretion caused by the river’s current, an alluvial deposit of approximately 1.9964 hectares formed adjacent to their titled property by 1958. Petitioners claimed ownership of this accretion by right of accession under the Civil Code.
Respondents Domingo and Esteban Calalung opposed this claim, asserting they had been in open, continuous, and adverse possession of the alluvial land since 1933 or 1934. Petitioners filed an action to quiet title and recover possession in 1958. The Court of First Instance ruled in favor of the petitioners, declaring the accretion belonged to them as riparian owners and ordering respondents to vacate.

ISSUE

The core issue is whether the alluvial formation, which by law (Article 457 of the Civil Code) ordinarily accrues to the riparian owner, can be acquired through acquisitive prescription by a third party, and whether such accretion is considered registered land immune to prescription.

RULING

The Supreme Court affirmed the Court of Appeals’ decision dismissing the petitioners’ action. The legal logic proceeds in two steps. First, the Court held that the alluvial property, despite being an accession to a titled parcel, does not automatically become registered land under the Torrens system. Registration is a distinct legal process; the mere fact of accretion does not extend the original certificate of title’s coverage or its imprescriptible character to the new formation. Since petitioners never sought registration of the accretion, it remained unregistered property.
Second, being unregistered, the land was susceptible to acquisitive prescription. The Court of Appeals’ factual finding that respondents had possessed the land openly, continuously, and under a claim of ownership since 1933 or 1934—a period exceeding the required prescriptive period—was deemed conclusive. The applicable law on prescription was Act No. 190 (the Code of Civil Procedure), as the possession commenced before the effectivity of the new Civil Code. Consequently, respondents acquired ownership through ordinary acquisitive prescription, which constitutes a “superior title” that supersedes the petitioners’ right of accession. The law of accession yields to a perfected prescriptive title.