G.R. No.

L-6098 August 12, 1911

THE INSULAR GOVERNMENT, plaintiff-appellee,
vs.
ALDECOA AND COMPANY, defendant-appellant.

FACTS:

• Aldecoa & Co. illegally occupied two parcels of land belonging to the government for the
past seventeen years.
• Aldecoa & Co. constructed a wharf, warehouses, and other structures on the land for
their exclusive use and benefit.
• The Insular Government filed a complaint to recover possession of the land and
requested that the defendant be ordered to return it to the government.

ISSUE:

• Whether the defendant had the right to occupy and claim ownership of the land formed
by the action of the sea.

RULING:

• The court ruled in favor of the Insular Government.

• The defendant's occupation of the land without proper authorization from the government
was deemed illegal and a mere detainer.
• The land in question belonged to the public domain and was intended for public uses.
• Lands formed by accretion and alluvium deposits caused by the sea are not susceptible
to prescription and remain part of the public domain until converted into patrimonial
property of the state.

RATIO:

• The court cited the Law of Waters of August 3, 1866, which governs the ownership and
use of seashore lands in the Philippines.
• According to the law, lands formed by the action of the sea belong to the national domain
and are for public use.
• The government may declare them to be the property of adjacent landowners if they are
no longer necessary for administrative purposes and public utility.
• No private person is allowed to construct works on the seashore without proper
authorization from the government.

DISTUINGUISHING FACTORS:

• The court distinguished this case from previous decisions, stating that the lands formed
by the action of the sea are not the same as mangrove-swamplands or agricultural lands.
• The defendant's claim of ownership based on a verbal permit from a politico-military
governor was not valid, as the governor did not have the authority to grant ownership of
public lands.
CONCLUSION:

• The court affirmed the judgment of the lower court, ordering the defendant to return the
illegally occupied land to the government.
• The defendant was also ordered to pay the costs of the case.

BASIS OF THE COURT’S DECISION:

• The court based its decision on the Law of Waters of August 3, 1866.
• According to this law, lands formed by the sea and the adjacent shore are part of the
national domain and are intended for public uses.
• The court emphasized that no private person is allowed to construct or perform any
works on the seashore to gain land for their benefit without proper authorization from the
government.

ILLEGAL OCCUPATION AND MERE DETAINER:

• The court stated that the occupation or possession of any land formed upon the shore
without permission from the proper authorities is illegal.
• Such occupation is considered a mere detainer, meaning it does not confer any legal
rights to the occupier.
• The land in question is outside the sphere of commerce and belongs to the national
domain for the benefit of those who live nearby.

LAND FORMED BY THE SEA AND PRESCRIPTION

• The court explained that lands formed by the action of the sea, along with the adjacent
shore, are not subject to prescription.
• Prescription refers to the acquisition of rights through the passage of time.
• As long as these lands continue to be set apart for public uses, they cannot be acquired
through prescription.
• The court distinguished this case from previous decisions, stating that the lands in
question were not the same as lots, fisheries, and nipa lands that are ordinarily inundated
by the sea.