Cansino v. Valdez
REITERATIONFacts
The Antecedents: Plaintiffs-appellees, Magdalena Cansino et al., purchased property in question as public lands from the Spanish Government on October 27, 1893. Defendants-appellants claimed ownership of the same land by extraordinary prescription, testifying that they took possession in 1862. None of the occupants had any written title to the land. Procedural History: The case was decided by the Supreme Court on April 30, 1906, with the grounds for the decision being laid out in the present judgment. The Petition: The defendants-appellants appealed the decision of the lower court.
Issue(s)
Whether title to land, while property of the State, can be acquired by prescription.
Ruling
The Supreme Court affirmed the judgment of the lower court, holding that title to lands, while they remain the property of the State, cannot be acquired by prescription.
Ratio Decidendi
On Whether title to land, while property of the State, can be acquired by prescription: The Court held that title to lands, while they remain the property of the State, cannot be acquired by prescription. This ruling is based on the principle established in the case of Valenton vs. Murciano, 2 Off. Gaz., 434, decided on March 30, 1904. In that case, it was determined that prescription does not run against the State. The facts of the present case are almost identical to Valenton vs. Murciano, involving adjoining tracts of land, one in Pangasinan and the other in Tarlac. In both cases, the defendants purchased land from the Spanish Government, but at different dates. The plaintiffs in Valenton vs. Murciano went into possession in 1860, claiming ownership by thirty years' extraordinary prescription, while in the present case, some defendants testified to possession since 1862, also claiming ownership by the same extraordinary prescription. Crucially, in neither case did the occupants possess any written title to the land. The Court reiterated that the decision in Valenton vs. Murciano governs and controls this case, leading to the affirmation of the judgment.
Main Doctrine
Title to lands, while property of the State, cannot be acquired by prescription.