Heirs of Emiliano Navarro… · G.R. 68166

Petitioner: Heirs of Emiliano Navarro
Respondent: Intermediate Appellate Court
Citation: G.R. No. 68166
Court: Supreme Court
Division: First Division
Ponente: Vitug, J.
Decided: February 12, 1997

Summary

This case involved competing claims over a 14.6-hectare tract in Balanga, Bataan, formed adjacent to registered property bounded by two rivers and Manila Bay. The Heirs of Pascual claimed it as accretion from river action benefiting the riparian owner under Civil Code Article 457, while the Heirs of Navarro argued it was foreshore land under government lease. The Supreme Court determined the land was actually an accretion on a sea bank (Manila Bay), formed through the combined effects of tree planting, bay water withdrawal, and tidal action. Under Article 4 of the Spanish Law of Waters of 1866, such sea accretions belong to the public domain unless specifically declared otherwise by competent government authority. The Court distinguished this from river accretion cases and emphasized that Manila Bay, being an inlet of the sea, required different legal treatment than lake accretions.

Statutes applied

Civil Code, Art. 457

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Leonida Cureg v. Intermediate Appellate Court G.R. No. 73465
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By the Intellegal Editorial Board · February 12, 1997

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