GR 92161; (March, 1991) (Digest)
G.R. No. 92161 ; March 18, 1991
SIMPLICIO BINALAY, et al., petitioners, vs. GUILLERMO MANALO and COURT OF APPEALS, respondents.
FACTS
Respondent Guillermo Manalo purchased two parcels of land from the successors of the late Judge Taccad, totaling 10.45 hectares, bordering the Cagayan River. A cadastral survey during the rainy season designated a consolidated dry area as Lot 307 (4.6489 hectares). An adjacent strip of land, formed between two seasonal branches of the river, was designated as Lot 821 (11.9087 hectares). This Lot 821 is dry and cultivable for about eight months annually but is separated from Manalo’s Lot 307 by the eastern river bed, which is submerged during the rainy season.
Manalo filed a complaint for quieting of title, claiming ownership of Lot 821 by accretion to his property. Petitioners, who were in possession of and cultivating Lot 821, opposed this claim. The trial court and the Court of Appeals ruled in favor of Manalo, declaring him the owner of Lot 821 and ordering petitioners to vacate.
ISSUE
Whether respondent Manalo has established ownership over Lot 821, such that he is entitled to the remedy of quieting of title and possession against the petitioners.
RULING
No. The Supreme Court reversed the Court of Appeals. The Court held that Manalo failed to prove sufficient title or interest to sustain an action for quieting of title over Lot 821. For such an action under Article 477 of the Civil Code, the plaintiff must demonstrate at least an equitable title to or interest in the property. The evidence showed Manalo’s prior possession was limited to Lot 307 and the regularly submerged eastern river bed, not to Lot 821. His earlier forcible entry cases also pertained only to those areas, not to Lot 821.
Crucially, the Court ruled that the eastern river bed, being a seasonal branch of the Cagayan River that carries water during the rainy season, is part of a public river and thus property of public dominion under Article 420 of the Civil Code. It cannot be owned privately. Since Lot 821 is separated from Manalo’s Lot 307 by this public river bed, the claim of accretion under Article 457 of the Civil Code fails. Accretion only applies to lands adjacent to the riverbank, not to lands separated by the river itself. Therefore, ownership of Lot 821 could not be adjudicated in this proceeding and must be determined in a separate appropriate action. The Court declared Manalo owner only of Lot 307 and declared the eastern river bed as public dominion.