Facts:

The case at hand, Nazaria Alcala et al. vs. Bartolome Alcala et al., involves two interconnected civil cases (Nos. 174 and 175) that were appealed from the Court of First Instance of Mindoro. The initial complaint was filed on July 20, 1914, by the children and grandchildren of the deceased Jose Alcala, namely Francisco and Nazaria Alcala, as well as their grandchildren (Simeon Abao, Generosa Abao, Guillermo Abay, and Silvina Abay) against Bartolome, Tomas, and Isidora Alcala, who are the children of Rosendo Alcala (another son of Jose Alcala). Jose Alcala passed away in 1870, leaving behind several parcels of real property, which were not partitioned upon his death. Instead, Rosendo Alcala was entrusted with the administration of these properties owing to his education and ability. Upon Rosendo’s death in 1902, his children took control, claiming the properties as their own and failing to share the proceeds with the other rightful heirs despite the initial agreement for co-owne

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Facts:

Background and Context

• The case consolidated two civil actions (Nos. 174 and 175) from the Court of First Instance of Mindoro, both originally decided on December 31, 1914.
• The disputes involve the partition and administration of the hereditary property left by Jose Alcala, who died in 1870, in the pueblo of Calapan, Mindoro.

Parties Involved

• Plaintiffs (and appellants in part):
• Francisco and Nazaria Alcala (children of Jose Alcala), with Nazaria married to Vicente Jurado.
• Grandchildren represented by:
• Simeon Abao and Generosa Abao (children of Maria Alcala, deceased) – with Generosa assisted by her husband, Maximo Gerera.

ii. Guillermo Abay and Silvina Abay (children of Laureana Alcala, deceased).

Allegations and Causes of Action

• In the first complaint (Case No. 174):
• Plaintiffs alleged that the deceased Jose Alcala left intact certain pieces of real property (a building lot and several parcels of land) that had not been properly divided among his children.
• It was contended that upon the death of coheir Rosendo Alcala, his descendants took possession and began to treat the property as their exclusive inheritance, subsequently failing to distribute the proceeds from its annual income (alleged to be about P 1,500 per year) to the other lawful heirs.
• A further cause of action charged that Rosendo Alcala, despite an agreement among the surviving heirs to secure joint title through possessory information proceedings, fraudulently procured a possessory title solely in his own name, thereby excluding the coheirs from rightful participation.
• In the second complaint (Case No. 175):
• Vicente Jurado and his wife Nazaria Alcala claimed possession and sought delivery of a parcel of land described as containing 1212 hectares in the sitio of Silonay, Calapan.
• They further demanded damages amounting to P 3,000 for alleged wrongful seizure and cultivation by the defendants.
• Defendants’ Response and Special Defenses
• The defendants denied all allegations in both complaints.
• They asserted a long history of possession (allegedly adverse, uninterrupted, and from time immemorial) over the property and claimed that even the alleged property rights of the plaintiffs had prescribed.
• Specifically for the second complaint, they maintained that the land in question was owned pro indiviso by them and that any claims by Vicente Jurado were either time-barred or lacked proper identification of the property.

Administration and Possessory Information Proceedings

• After Jose Alcala’s death, his entire estate became the subject of an extrajudicial arrangement whereby Rosendo Alcala was designated as administrator because of his superior education.
• In 1895, Rosendo Alcala initiated possessory information proceedings to secure title to the inherited lands; however, he did so solely in his own name, omitting the names of his coheirs despite an active agreement among the siblings.
• Although the possessory information was approved and registered (Exhibit 1), it contained the clause “without prejudice to a third person having a better claim,” thereby leaving intact the rights of the other heirs.

Developments Leading to Litigation

• Prior to 1906, Rosendo Alcala and later his children routinely rendered accounts of the income derived from the estate among all coheirs.
• After 1906, the defendants purportedly ceased sharing the proceeds, prompting the plaintiffs to file their complaints to enforce their right to a partition of the property and an accounting of the income.
• In addition, discrepancies arose concerning a subsequent sale by Bartolome Alcala (one of the defendant children) of a parcel in Batino, which further validated the plaintiffs’ claim that the defendants had acknowledged the coheirs’ rights by distributing the sale proceeds among them.

Issue:

Partition and Inheritance Rights

• Whether the estate left by Jose Alcala had not been partitioned and should, therefore, be distributed among his heirs in accordance with the law (arts. 926, 927, 932‑934, Civil Code).

Validity and Effects of the Possessory Information Title

• Whether Rosendo Alcala’s act of obtaining a possessory information title solely in his own name, without notifying or including his coheirs, legally validates the title despite its “prima facie” evidential nature.
• Whether the possessory information title, given its inherent clause and nature, is conclusive in establishing ownership over the disputed lands.

Prescription and Possession

• Whether the prolonged possession by the defendants (and their father) leads to acquisition of title by prescription in respect to the lands, or if their possession—as part of a joint hereditary property—prevents such prescription.

Identification and Specificity of the Claimed Property

• With regard to the separate claim by Vicente Jurado and his wife in Case No. 175, whether the specific parcel of land (claimed to be 1212 hectares) is adequately identified and proven, or whether the claim fails on the grounds of indefiniteness and lack of conclusive proof.

Ruling:

• (Subscriber-Only)

Ratio:

• (Subscriber-Only)

Doctrine:

• (Subscriber-Only)