Aquino v. Municipality of Bayambang
REITERATIONFacts
The Antecedents: Bernabe B. Aquino filed a case to recover real property from the Municipality of Bayambang. Concurrently, a land registration case was filed for the same property under Act No. 496. The Municipality of Bayambang claimed ownership of the fisheries, asserting ownership from time immemorial. Aquino based his claim on a deed of sale from Agustin V. Gomez, who purchased the property from Getulio Pitco, who in turn bought it from Juan Fajardo. Juan Fajardo had obtained a possessory information for the property in 1892. Witnesses testified to the continuous cultivation and possession of the property by Juan Fajardo and his successors. Procedural History: The cases were tried together. The lower court rendered a decision from which both Bernabe B. Aquino and the Municipality of Bayambang appealed. The Petition: Both appellants assigned errors in the decision of the lower court. Aquino asserted his ownership based on purchase and prior possession by his predecessors. The Municipality of Bayambang maintained its claim of immemorial ownership.
Issue(s)
Whether the Municipality of Bayambang presented sufficient evidence to establish its ownership and possession of the property prior to 1928. Whether Bernabe B. Aquino sufficiently proved his title to the property based on his purchase and the possessory information obtained by his predecessor in interest. Whether the possessory information, registered in 1920, is valid evidence of possession for claims predating its registration. Whether the claim for damages by the Municipality of Bayambang against Aquino is sufficiently proven. Whether Aquino's claim for damages against the Municipality of Bayambang is sufficiently proven.
Ruling
The Supreme Court modified the appealed judgment. It held that the land in litigation is not public land but belongs exclusively to Bernabe B. Aquino, who is entitled to have the proper title issued to him. The injunction against the municipality was held to be in force forever, and the adjudication of damages to the municipality was reversed. The judgment was affirmed in so far as it denied title to the municipality.
Ratio Decidendi
On the Municipality of Bayambang's claim: The Court found insufficient evidence to show the municipality's possession of the property prior to 1928. It was also not shown that the Insular Government had duly transferred the property to the municipality. The Court reiterated its holding that mere occupation and possession of land, along with the collection of rents, do not grant a municipality title thereto, citing previous cases. Therefore, the municipality's claim was found to be without merit. On Bernabe B. Aquino's claim: The Court found sufficient evidence that the property in litigation was the same parcel described in the possessory information obtained by Juan Fajardo. The boundaries, including a road that no longer exists, were sufficiently identified through witness testimonies. The Court held that the value of the possessory information as evidence of possession is not impaired by its late registration in 1920, as it was duly recorded when presented in court. The Court noted that the land is agricultural and that Aquino and his predecessors had been in possession as owners, publicly and continuously, dating back to 1887. The successive transfers of the land were clearly established. Consequently, under paragraph (b), section 45 of Act No. 2874, Bernabe B. Aquino is entitled to the land. On the validity of the possessory information: The Court clarified that while a possessory information might not avail against a third person before its recordation, its validity as evidence of possession is established once it is duly recorded in the registry of deeds, as was the case when it was presented in court. The Court found that the explanation provided by Marciano Fajardo regarding the 1911 survey sufficiently addressed the municipality's contention that he recognized the property as belonging to them. The survey was for boundary demarcation, not an assertion of ownership. On claims for damages by the Municipality of Bayambang: The Court found the municipality's claim for damages to be unfounded. It was not shown that the alleged damages were caused by persons acting under the municipality's order, either officially or maliciously. On claims for damages by Bernabe B. Aquino: The Court found Aquino's claim for damages against the municipality to be insufficiently proven. Similar to the municipality's claim, there was no evidence that the alleged damaging acts were performed pursuant to any official order or malicious intent from the municipality.
Main Doctrine
A possessory information, even if registered late, can serve as evidence of possession for purposes of establishing title, provided it is duly recorded at the time it is adduced in court. Mere occupation and possession of land by a municipality, without more, do not confer title.