Clemente v. Marasigan
REITERATIONFacts
The Antecedents: Plaintiff-appellant Celestino Sytiar Clemente instituted an action to recover possession of a parcel of land. Procedural History: The court below rendered judgment in favor of the defendant-appellee, Ambrosio Marasigan, who was in possession of the land. The Petition: The plaintiff-appellant appealed the decision of the lower court.
Issue(s)
Whether the defendant-appellee has established a prescriptive title to the land in question.
Ruling
The judgment appealed from is affirmed, with costs against the appellant.
Ratio Decidendi
On Issue 1: The evidence of record fully and sufficiently sustains the findings of fact by the trial judge, and upon these findings the judgment rendered by him must be affirmed. The evidence discloses, beyond any question, that the defendant and his antecedents in interest have been in quiet, peaceable, and uninterrupted possession of the land in question, under a claim of ownership, for a long period of years. The defendant himself has been in possession since the year 1894, when he bought it from one Icaza, who was then in possession. The deed of sale was initially executed in a private document, which was later ratified and affirmed in a public document by the heirs of Icaza, who were then deceased, on July 19, 1902. This action was instituted on October 29, 1906. It is clear that without going any further back than the occupation of the defendant himself, he must be held to have established his prescriptive title to the land in question. This is in view of his quiet, peaceable, and uninterrupted possession thereof, under a claim of ownership, for more than ten years. Furthermore, he acquired the land in good faith by purchase from one who himself was in possession under a bona fide claim of ownership.
Main Doctrine
A party who has been in quiet, peaceable, and uninterrupted possession of a land under a claim of ownership for more than ten years, having acquired the land in good faith by purchase from one who was in possession under a bona fide claim of ownership, has established a prescriptive title to the land.