Jose Reynante v. The Honorable Court of Appeals
REITERATIONFacts
The Antecedents: Petitioner Jose Reynante was a tenant for over 50 years of a fishpond owned by the late Don Cosme Carlos. During his tenancy, Reynante constructed a nipa hut and planted nipa palms on adjacent lots (Lots 1 and 2) which were located between the fishpond and a river. He harvested and sold these nipa palms without interference. After Don Cosme Carlos's death, his heirs (private respondents' predecessors) entered into an agreement with Reynante, wherein Reynante, for P200,000.00, surrendered his rights as tenant and caretaker of the fishpond and its structures. Reynante continued to reside in his nipa hut on Lots 1 and 2 and tend to his nipa palms. The private respondents later leased the fishpond to a third party. Procedural History: On February 17, 1988, private respondents demanded that Reynante vacate Lots 1 and 2, asserting he had been compensated for surrendering his tenancy rights. Reynante refused. Consequently, on April 22, 1988, private respondents filed a complaint for forcible entry against Reynante, alleging he had taken possession of Lots 1 and 2 through stealth and strategy. The Municipal Trial Court dismissed the complaint, finding Reynante had prior possession of these lots. The private respondents appealed to the Regional Trial Court, which reversed the Municipal Trial Court's decision, ordering Reynante to restore possession of Lots 1 and 2 and the nipa palms thereon. Reynante then filed a petition for review with the Court of Appeals, which affirmed the Regional Trial Court's decision. The Court of Appeals later denied Reynante's motion for reconsideration. The Petition: This case is a petition for review on certiorari filed by Jose Reynante seeking to reverse the decision of the Court of Appeals, which affirmed the Regional Trial Court's order for Reynante to vacate Lots 1 and 2. Reynante argues that he had prior physical possession of Lots 1 and 2, having occupied and cultivated them for over 50 years, and that the agreement to surrender the fishpond did not include these adjacent lots. He further contends that even if the lots were formed by accretion, the private respondents' failure to register them for such a long period subjected them to acquisition by prescription. The core issues before the Supreme Court are who has prior physical possession of Lots 1 and 2 and whether these lots belong to the private respondents by accretion.
Issue(s)
Who between the petitioner and private respondents has prior physical possession of lots 1 and 2? Whether or not the disputed lots belong to private respondents as a result of accretion, and if so, whether their failure to register the accretion subjected it to acquisition by prescription.
Ruling
The decision of the respondent Court of Appeals is REVERSED and SET ASIDE, and the decision of the Municipal Trial Court of Meycauayan, Bulacan, Branch I, is REINSTATED. Petitioner Jose Reynante is entitled to retain possession of Lots 1 and 2.
Ratio Decidendi
On the issue of prior physical possession: The Court held that an action for forcible entry is a quieting process where actual title is not determined; the party with prior possession can recover it even against the owner. The evidence showed petitioner had been in possession of Lots 1 and 2 for over 50 years, constructing a nipa hut and planting nipa palms. This possession was supported by affidavits of disinterested parties and observations made during an ocular inspection by the trial court. The trial court's observation that the disputed premises were beyond the titled property of the private respondents and situated along the river, possibly part of the public domain, further supported the petitioner's claim. The written agreement for the surrender of the fishpond did not explicitly include the nipa hut or the land where it was constructed, indicating that the surrender was limited to the fishpond itself and not the adjacent lots where the petitioner had established his prior possession. On the issue of accretion and prescription: The Court noted that the disputed lots were not included in the private respondents' Transfer Certificate of Title No. 25618 and were identified as falling within Alienable and Disposable Land. While the Court of Appeals ruled that the lots were created by alluvial formation and thus belonged to the private respondents under Article 457 of the Civil Code, the Supreme Court clarified that accretion to registered land does not automatically make the accreted area registered. Ownership of accretion is governed by the Civil Code, but registration under the Torrens system requires judicial procedures. The Court cited Ignacio Grande, et al. v. Hon. Court of Appeals, et al., stating that an accretion does not automatically become registered land. Assuming private respondents acquired the alluvial deposit by accretion, their failure to register it for fifty years subjected the accretion to acquisition by prescription by third persons, such as the petitioner who had been in undisputed possession for over fifty years. Therefore, unless private respondents could show a better title, petitioner's possession must be respected.
Main Doctrine
A party who can prove prior physical possession can recover possession in a forcible entry case, even against the owner, as actual title is not determined. Failure to register an accretion for fifty years subjects it to acquisition by prescription.