GR L 2925; (December, 1950) (Digest)
G.R. No. L-2925 December 29, 1950
THE DIRECTOR OF LANDS, MATIAS NAREDO, VALENTIN NAREDO, and JUANA DE LEON, petitioners, vs. RICARDO RIZAL, POTENCIANA RIZAL, ELENA RIZAL, BENJAMIN RIZAL, and SATURNINA RIZAL, respondents.
FACTS
Lot No. 454 of the Calamba Friar Lands Estate was sold to Santos Alcaraz in 1910 under a certificate of sale, payable in installments. In 1916, Alcaraz assigned his rights to Severino Rizal, which was approved by the Bureau of Lands. Severino Rizal completed payment in 1930, after which a final deed of conveyance and certificate of title were issued. He died in 1934, and his heirs (respondents) succeeded to the property. Over approximately twenty years from 1916, accretion by alluvium from the adjacent San Juan River added about two hectares to the lot. From 1938 to 1942, petitioners (the Naredos) cultivated the accreted land as tenants of the Rizal heirs but later refused to surrender possession, claiming they had applied to the Bureau of Lands. The Director of Lands intervened, asserting the accretion belonged to the government. The trial court and Court of Appeals ruled in favor of the Rizal heirs.
ISSUE
Whether the accretion formed by alluvium to a Friar Lands lot, occurring before the full payment of the purchase price, belongs to the purchaser (or his successors) or to the government.
RULING
The accretion belongs to the purchaser (Severino Rizal and his heirs). Under Act No. 1120 (Friar Lands Act), while the government reserves legal title until full payment, the equitable and beneficial title passes to the purchaser upon issuance of the certificate of sale and payment of the first installment. The government’s reservation is merely a security for payment, and the purchaser assumes the benefits and risks of ownership during the installment period, including entitlement to accretions. The purchaser buys a definite parcel with fixed boundaries, and the adjoining river constitutes a natural boundary; any accretion thus becomes part of the property. The government’s role is akin to that of a lien holder, not an owner entitled to gains or liable for losses. The decision of the Court of Appeals was affirmed.
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