Facts:

The case revolves around Tranquilina Alcala and Segundo Alviedo as the plaintiffs and appellants against Pedro Hernandez and Potenciana Pacleb, the defendants and appellees. The dispute originates from a parcel of land known as "Nalbo," located in the municipality of Luna, Province of La Union. The plaintiffs allege that the defendants had been in possession of the land since 1894 and that on March 29, 1909, they sold the land to the defendants for P700. Following the sale, on August 11, 1911, Alcala sought to recover the value of the agricultural produce from the land, specifically claiming 120 uyones of rice, or an equivalent of P3,600, along with P1,000 for lost damages. However, the defendants contended that the sale should be annulled since they believed the property did not belong to Alcala at the time of sale, thereby requesting the return of the P700 purchase price. The Court of First Instance of La Union reviewed the case and dismissed the complaint, attributi

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Facts:

Parties and Transaction Background

• Plaintiff: Tranquilina Alcala, with her husband Segundo Alviedo acting in support.
• Defendants: Pedro Hernandez and Potenciana Pacleb.
• The dispute centers on a piece of land known as the Nalbo land, located in the municipality of Luna, Province of La Union, which is described solely based on its capacity to produce a crop of ten uyones of rice.

Land Possession and Sale Details

• The land had been in the possession of the defendants since 1894.
• On March 29, 1909, Tranquilina Alcala sold the land to the defendants for the sum of P700.
• The sale was executed through two instruments, each corresponding to an installment of the purchase price.

Claims and Subsequent Proceedings

• Plaintiff’s Claim:
• Initiated on August 11, 1911, seeking the fruits of the land accrued over a fifteen-year period (1894–1909), specifically 120 uyones of rice or its monetary equivalent of P3,600.
• Additionally, plaintiff sought P1,000 for losses and damages.
• Defendants’ Counterclaims:
• Argued that the sale should be avoided on the basis that the plaintiff did not actually own the subject land, as they mistakenly believed she owned it.
• Requested that the plaintiff refund the P700 paid for the land.
• Court Proceedings:
• The Court of First Instance of La Union tried the case and dismissed the complaint, with costs imposed on the plaintiff.
• The plaintiff appealed the decision, arguing that she had not waived her claim against the defendants regarding both the land and its products.

Deeds of Sale and Waiver Provisions

• Execution of Instruments:
• In the first instrument, the plaintiff’s husband declared that his wife “waives absolutely all the right she may have to the ownership” of the property.
• In the final deed of sale, Tranquilina Alcala acknowledged receipt of the total sum of P700 “to [her] entire satisfaction” and stated, “I absolutely will not raise any question whatsoever with reference to the property.”
• Additional Notations in the Deed:
• The instrument mentioned that part of the property had been in the possession of Leoncio Pacleb since 1872, and that possession had continued by Potenciana Pacleb since 1894.
• The deed incorporated a plan indicating the specific area conveyed, reinforcing the recognition of prior possession.

Evidentiary Basis and Legal Reference

• The trial judge relied on both the preponderance of evidence from the parties’ testimonies and the explicit tenor of the executed deeds (Exhibits B and C).
• The judgment also referenced the legal principle that “the fruits collected in good faith by a possessor during the time the possession is not legally interrupted become his own” (Civil Code, art. 451).
• There was recognition that the possession had never been legally interrupted since 1872, thereby strengthening the defendants’ claim of superiority in possession.

Issue:

• Whether the execution of the deeds of sale, which include explicit waiver provisions, effectively barred the plaintiff from asserting any claim over the land and its fruits.
• Whether the continuous and unchallenged possession by the defendants, beginning in 1872 (or 1894 for Potenciana Pacleb), and conducted in good faith, precluded the plaintiff’s claim for the fruits produced from the land.
• Whether the transaction could be nullified on the ground that the plaintiff did not possess valid title to the land, despite having executed waiver instruments.

Ruling:

• (Subscriber-Only)

Ratio:

• (Subscriber-Only)

Doctrine:

• (Subscriber-Only)