G.R. No. L‑2394
November 22 1906

FACTS
– Plaintiffs‑appellants (Ker & Co.) sought ejectment of a ~15‑hectare parcel at Sangley Point, Cavite, claiming title by conveyances of 1901‑02 from the owners of “Hacienda de la Estanzuela.”
– The land had been created by accretion of sand and vegetation over the past century; it did not exist in the 1811 survey, and only a portion appeared in the 1856 survey.
– Defendant‑appellee (A.R. Cauden), commander of the U.S. Cavite Naval Station, possessed the land and asserted title based on United States authority and on the Philippine Law of Waters (originally the Spanish law of 1866, applied in the Islands by royal orders of 1871‑73).
– The defendants raised (1) the statute of limitations and (2) a special defense that the land was public domain because it was formed by the sea’s accretion.
– At trial the plaintiffs admitted the accretion allegation but disputed the date of its commencement, leaving the question of ownership open.

ISSUE
Whether lands newly formed by the action of the sea (accretion) become part of the adjoining private estate by accession, or remain public property under the Law of Waters (Art. 4, § 1‑4), and consequently whether the plaintiffs’ claim is barred by the statute of limitations.

RULING
– The Court held that Art. 4, § 1 of the Law of Waters expressly declares lands gained by accretion to the beaches as public domain. The subsequent provisions merely provide that, when the State determines such lands are no longer needed for public purposes, it may grant them to adjacent private owners a grant that was never made here.
– The registry of deeds itself noted that the disputed portion was “ganado por aluvión” (land gained by sediment), alerting the plaintiffs that it was state property and that the grantors had no authority to convey it.
– Because the land was state-owned from its formation, the question of prescription (statute of limitations) was rendered moot.
– The judgment of the trial court in favor of the defendant‑appellee was affirmed, and the appellants were ordered to pay costs.

Result: Lands formed by accretion belong to the State unless a specific concession is granted; therefore, the plaintiffs’ title claim fails.