G.R. No. 222123 , June 28, 2021
AQUILINO MANIGBAS, PETITIONER, VS. MELO ABEL, FROILAN YLAGAN, AND DENNIS DE GUZMAN, RESPONDENTS.

FACTS

Petitioner Aquilino Manigbas is the registered owner of Lot 2070-K. The eastern portion of this lot serves as a barangay road, constructed by the Provincial Government of Oriental Mindoro under its power of eminent domain, but for which Manigbas has not received just compensation. Adjoining this barangay road is a 0.3112-hectare parcel of land accreted from the San Agustin River (the accreted lot). Manigbas requested a survey authority from the DENR-MIMAROPA for this accreted lot and subsequently filed a Free Patent Application (FPA). Respondents filed unverified protests, claiming irregularities in the survey and that the lot was subject to easement restrictions. An Investigation Report recommended amending the FPA to include a 20-meter legal easement. Initially, the DENR-MIMAROPA OIC-RTD sustained the protests, but the Regional Executive Director reversed this, setting aside the OIC-RTD’s order and directing Manigbas to follow up on the survey plan approval and file appropriate land registration proceedings. Respondents appealed to the DENR Secretary, who set aside the Regional Executive Director’s order, ruling Manigbas could not be the riparian owner as the accreted lot adjoined the barangay road portion of his property. The Office of the President and the Court of Appeals affirmed the DENR Secretary’s decision, with the CA emphasizing the provincial government’s expropriation powers over the road portion. Manigbas elevated the case to the Supreme Court via a Petition for Review on Certiorari.

ISSUE

Whether the Court of Appeals erred in affirming the decisions that withheld the approval of the Proposed Survey Plan for the accreted lot based on the allegation that it adjoins the barangay road portion of Manigbas’s property. Subsumed is the question of whether Manigbas, as the registered owner of the adjoining lot, is entitled to the accretion despite the existence of the barangay road.

RULING

The Supreme Court GRANTED the petition, ruling in favor of Manigbas. The Court held that the Court of Appeals ruled contrary to established law and jurisprudence. The Court explained that under Article 457 of the Civil Code, accretion (alluvion) belongs to the owners of lands adjoining the banks of rivers. The fact that a portion of Manigbas’s titled property was expropriated for use as a barangay road does not strip him of his ownership of the underlying land or his status as the riparian owner entitled to the accretion. The expropriation only resulted in an easement of right-of-way; the ownership of the land itself remained with Manigbas, subject to his right to just compensation. Consequently, as the owner of the land adjoining the riverbank, Manigbas is entitled to the alluvial deposit. The Court further clarified that the existence of a legal easement along the riverbank (a separate matter from the road easement) does not preclude ownership of the accreted land but merely imposes limitations on its use. The DENR’s role is limited to conducting the survey and investigation for the purpose of land registration; it cannot adjudicate ownership, which is a judicial function. The Court directed the DENR to approve the survey plan and for Manigbas to file the appropriate land registration proceedings in court.