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1) Ciriaco Imbornal convinced the Imbornal sisters to sell their land in Sabangan and used the proceeds to obtain a homestead patent for a riparian land called the Motherland.
2) A dispute arose between the heirs of Francisco Narvasa and the heirs of Pablo Imbornal over ownership of the Motherland and two accretions.
3) The Court ruled that Ciriaco did not hold the Motherland in implied trust for the Imbornal sisters. It also ruled that as the heirs of Pablo Imbornal were the riparian owners of the Motherland, they had preferential rights over the two accretions.
1) Ciriaco Imbornal convinced the Imbornal sisters to sell their land in Sabangan and used the proceeds to obtain a homestead patent for a riparian land called the Motherland.
2) A dispute arose between the heirs of Francisco Narvasa and the heirs of Pablo Imbornal over ownership of the Motherland and two accretions.
3) The Court ruled that Ciriaco did not hold the Motherland in implied trust for the Imbornal sisters. It also ruled that as the heirs of Pablo Imbornal were the riparian owners of the Motherland, they had preferential rights over the two accretions.
1) Ciriaco Imbornal convinced the Imbornal sisters to sell their land in Sabangan and used the proceeds to obtain a homestead patent for a riparian land called the Motherland.
2) A dispute arose between the heirs of Francisco Narvasa and the heirs of Pablo Imbornal over ownership of the Motherland and two accretions.
3) The Court ruled that Ciriaco did not hold the Motherland in implied trust for the Imbornal sisters. It also ruled that as the heirs of Pablo Imbornal were the riparian owners of the Motherland, they had preferential rights over the two accretions.
Victoriano Ciriaco, with the help of his wife, was
Digest by: Trisha Cruz able to convince the Imbornal sisters to sell the Sabangan property; FACTS: Ciriaco used the proceeds from the sale Basilia Imbornal had four children, Alejandra, of the Sabangan property to fund his Balbina, Catalina, and Pablo, and from those homestead patent on the Motherland; arose the following heirs: Once the patent on the Motherland is Heirs of the Francisco Narvasa— approved, Ciriaco Imbornal is deemed to descendants of the Alejandra and be holding such property in trust for the Balbina Imbornal Imbornal sisters.
Heirs of Pablo Imbornal—descendants Also, the heirs of Francisco Narvasa further
of Pablo Imbornal alleged that through deceit, fraud, falsehood and misrepresentation, the heirs of Pablo Imbornal [Sabangan Property] had illegally registered the said accretions in During her lifetime, Basilia owned a parcel of their names—notwithstanding that they were land situated at Sabangan, Barangay Nibaliw not riparian owners. West, San Fabian, Pangasinan with an area of 4,144 sq. m.), more or less (Sabangan property), which she conveyed to her three (3) daughters ISSUE: Balbina, Alejandra, and Catalina (Imbornal sisters) sometime in 1920. W/N THE HEIRS OF FRANCISCO NARVASA OWN THE MOTHERLAND (RIPARIAN LAND) [Motherland] ALONG WITH THE SUBSEQUENT On the other hand, the husband of Catalina ACCRETIONS? Imbornal, namely Ciriaco Abrio, was granted a NO homestead patent over a 31, 367 sq. meter riparian land adjacent to the Cayanga River, HELD: Pangasinan. The Court first ruled over the existence of a valid Consequently, the heirs of Ciriaco Abrio implied trust between Ciriaco and the Imbornal occupied the northern portion of the sisters. Motherland, Implied Trust: There is no implied Trust On the other hand, the heirs of Pablo Imbornal occupied the southern portion of the land. Article 1456 of the Civil Code states that "[i]f There were two accretions that occurred through property is acquired through mistake or fraud, the course of time: the person obtaining it is, by force of law, considered a trustee of an implied trust for the 1st Accretion—occurred during 1949 and benefit of the person from whom the property adjoined the southern portion of the comes." Motherland. A TCT was issued Victoriano, who is one of the heirs of Pablo Imbornal; In this case, it cannot be said that, through oral evidence that Ciricao was merely a trustee of an 2nd Accretion—occurred during 1971 and implied trust holding the Motherland for the abutted the First accretion on the southern benefit of the Imbornal sisters or their heirs. portion of the Motherland. The TCT was issued in the name of all the heirs of Pablo Imbornal. Weighed against the presumed regularity of the award of the homestead patent to Ciriaco and The heirs of Francisco Narvasa filed an Amended the lack of evidence showing that the same was Complaint for reconveyance, partition and/or acquired and registered by mistake or through damages against the heirs of Pablo Imbornal. fraud, the oral evidence of the heirs of Francisco Narvasa would not effectively establish their The heirs of Francisco Narvasa anchored their claims of ownership. claim on the following allegations: Not Riparian owners; thus not owners of the accretion
Subsequently, the Court further held that as the
heirs of Francisco Narvasa failed to prove their ownership rights over the Motherland, their cause of action with respect to the First Accretion and, necessarily, the Second Accretion, must likewise fail.
The heirs of Francisco are not the owners of the
two accretions
Article 457 of the Civil Code states the rule on
accretion as follows: "[t]o the owners of lands adjoining the banks of rivers belong the accretion which they gradually receive from the effects of the current of the waters."
Therefore, being the owner of the land adjoining
the foreshore area, the heirs of Pablo Imbornal are the riparian owners, and they have preferential rights over the accretions.