HEIRS OF NAVARRO V. IAC
268 SCRA 74
Pascual filed an application for lease of a foreshore land. Such was denied. Navarro then sought approval for fishpond application which was consequently approved. Pascual then later sought registration of land, he claims to be from accretion. His application was denied for land sought to be registered is public domain.
Accretion through the action of the sea forms part of the public domain.