Paulino-Marcelo v. Court of Appeals
REITERATIONFacts
1. The Antecedents: The underlying dispute concerns the ownership and possession of a portion of unregistered land in Sta. Lucia, Angat, Bulacan. Petitioners, heirs of the deceased Jose Marcelo, claim that respondents Fernando Cruz and Servando Flores encroached upon approximately 7,540 square meters of their parents' land, which was declared for taxation purposes under Tax Declarations No. 2880 and No. 2882. The petitioners assert continuous possession of their property since 1939. 2. Procedural History: The heirs of Jose Marcelo filed an action for recovery of the disputed land with the Regional Trial Court (RTC) of Malolos, Bulacan, on October 6, 1982, later amending their complaint on October 12, 1983. The RTC ruled in favor of the petitioners, ordering respondents Cruz and Flores to return ownership and possession of the 7,540 square meters and to pay attorney's fees. Respondents appealed to the Court of Appeals, which reversed the RTC's decision, finding that respondent Servando Flores had acquired ownership of the disputed land by ordinary acquisitive prescription. Petitioners' motion for reconsideration was denied, leading to the present petition. 3. The Petition: Petitioners seek a review on certiorari of the Court of Appeals' decision, arguing that the appellate court erred in applying the doctrine of acquisitive prescription. They contend that the respondents never lawfully acquired the 7,540 square meters, as the land sold to respondent Cruz by the Sarmientos purportedly only covered 6,800 square meters, and that the appellate court disregarded the trial court's factual findings contrary to the evidence. Petitioners specifically cite Tero vs. Tero and assert that the respondents cannot account for how they acquired the disputed lot, while petitioners have proven it was part of their parents' land possessed since 1939.
Issue(s)
Whether respondent Servando Flores acquired ownership of the disputed 7,540 square meters of land through ordinary acquisitive prescription. Whether the Court of Appeals erred in reversing the findings of fact of the Regional Trial Court.
Ruling
The petition is denied. The Court affirms the decision of the Court of Appeals, holding that respondent Servando Flores acquired ownership of the disputed land through ordinary acquisitive prescription.
Ratio Decidendi
On the issue of acquisitive prescription: The Court held that respondent Servando Flores acquired ownership of the disputed 7,540 square meters through ordinary acquisitive prescription. The Court found that Flores took possession of the controverted portion in good faith and with just title, as it was an integral part of the larger tract of land he bought from Fernando Cruz under a public document. The deed of sale explicitly included the disputed portion referred to as "parang." At the time of the sale in 1968, the entire area was already covered by a tax declaration in the name of Fernando Cruz and had been surveyed in his favor. Therefore, Flores's possession of the entire parcel, including the disputed portion, was in the concept of an owner, and it was public, peaceful, and uninterrupted. This possession lasted for almost fourteen (14) years before the petitioners initiated their complaint in 1982, satisfying the requirements for ordinary acquisitive prescription under Article 1134 of the Civil Code, which requires possession for ten years with good faith and just title. On the issue of disregarding the findings of fact of the RTC: The Court found no cogent reasons to reverse the findings of the Court of Appeals. The appellate court correctly interpreted the "Kasulatan ng Partisyon sa Labas ng Hukuman at Bilihang Patuluyan" dated March 19, 1960, which clearly indicated that the sale to respondent Cruz covered both the "palayero" (riceland) and the "parang" (pasture land). The document explicitly described the "parang" as having an area of 7,856 square meters and listed Jose Marcelo as one of the adjoining owners to the west. This contradicted petitioners' claim that the "parang" was not included in the sale. Furthermore, respondent Cruz declared both parcels for taxation purposes in 1960, and respondent Flores subsequently took possession and paid taxes on the entire 13,856 square-meter property, reinforcing the conclusion that the "parang" was indeed part of the property acquired by respondents.
Main Doctrine
The Court of Appeals correctly ruled that respondent Flores acquired ownership of the disputed land through ordinary acquisitive prescription, as his possession was in good faith, with just title, and had been public, peaceful, and uninterrupted for almost fourteen (14) years prior to the filing of the complaint.