Republic of the Philippines v. Arcadio Ivan A. Santos Iii

Summary

The Supreme Court reversed lower courts' grant of land registration for Lot 4998-B in Parañaque City, ruling that respondents could not claim ownership through accretion under Civil Code Article 457. The Court distinguished between accretion (gradual soil deposit through water current effects) and the actual situation where the Parañaque River simply dried up. Evidence showed the 1,045 square meter property was a dried-up river bed, not land formed through accretion. Under Articles 420 and 502 of the Civil Code, rivers and their natural beds are public dominion belonging to the State. The Court held that dried-up river beds remain State property unless expressly granted to private persons by law. Respondents failed to prove alienable and disposable classification or establish requisite adverse possession. The decision reinforces the Regalian doctrine that all lands not clearly within private ownership are presumed to belong to the State, and that property of public dominion cannot be acquired through prescription without government declaration of alienability.