Facts:

The case involves plaintiffs Jose Alcantara, Elias Benin, Pascual Pili, Alejandro de Dios, Tomas Bagagonio, Quintina Sandoval, and Tomasa Lazaro as the appellants, and Mariano Tuazon y de la Paz, the heirs of Mariano Tuazon, J. M. Tuazon & Co., Inc., and Gregorio Araneta, Inc. as the appellees. The events that led to this case took place in Quezon City, where the plaintiffs claimed ownership of certain parcels of land situated along Bonifacio Street, which they asserted had been in their continuous and uninterrupted possession from time immemorial. The controversy arose when, on July 8, 1914, the defendants obtained a certificate of title (No. 375) over one of these parcels, which encompassed the lands claimed by the plaintiffs. The plaintiffs contended that they had enjoyed ownership of the land for over thirty years prior to the title's issuance. On June 23, 1950, they alleged that the defendants removed two houses from their land without consent. The plaintiffs argued

...

Facts:

Parties and Background

• Plaintiffs: Jose Alcantara, Elias Benin, Pascual Pili, Alejandro de Dios, Tomas Bagagonio, Quintina Sandoval, and Tomasa Lazaro, who claim to be the owners of certain parcels of land along Bonifacio Street in the barrio of San Jose, Quezon City.
• Defendants: Mariano Tuazon y De la Paz, heirs of Mariano Tuazon; J. M. Tuazon & Co., Inc.; and Gregorio Araneta, Inc.

Alleged Ownership and Possession

• Plaintiffs allege that from time immemorial they have been in actual, open, and continuous possession and enjoyment of the parcels without any molestation by the defendants.
• The plaintiffs assert that both they and their predecessors in interest enjoyed full ownership rights well before any questioning of title occurred.

Certificate of Title and Registration Proceedings

• Defendants obtained a certificate of title (No. 375) on July 8, 1914, through registration proceedings that incorporated the parcels of land claimed by the plaintiffs.
• The plaintiffs contend that their lands, which had been possessed and enjoyed as their own for more than 30 years before the issuance of the title, were erroneously included in the registration proceedings.
• It was argued that the registration process was conducted without formally notifying or affording due process to the plaintiffs, thereby violating constitutional protections.

Incidents Leading to the Litigation

• On June 23, 1950, the defendants allegedly caused the removal of two houses belonging to the plaintiffs on the disputed land.
• Subsequent to the defendants obtaining the title and the removal of the houses, the plaintiffs argued that the defendants’ conduct and the manner of registration proceedings effectively extinguished any right the plaintiffs might have had to claim ownership by prescription.

Amended Complaint and Additional Allegations

• After the original complaint was dismissed on the ground that the action was barred by the statute of limitations, the plaintiffs filed an amended complaint.
• The amended complaint reiterated the earlier allegations and added that:
• Plaintiffs only became aware in January 1950 that their lands were included in the registration proceedings leading to the issuance of the title.
• Defendants had never explicitly claimed ownership of the land but rather allowed the plaintiffs to continue its use, implying a form of tolerance.
• Both the amended complaint and a motion for reconsideration were denied, prompting the appeal.

Issue:

Statutory Limitations and the Effect of Time

• Whether the action for the recovery of the land is barred by the statute of limitations based on the lapse of time before the plaintiffs took legal action.
• Whether the plaintiffs’ claim based on their alleged 30-year possession over the land can override the statute even after the registration proceedings.

Notification and Due Process in Registration Proceedings

• Whether the plaintiffs, as occupants, were properly notified about the registration proceedings that led to the issuance of the defendants’ certificate of title.
• Whether the failure to receive notice or to act before the registration proceedings can excuse the plaintiffs from the binding effects of the registration.

Possessory Acts and Their Legal Implications

• Whether the alleged permissive conduct of the defendants—allowing the plaintiffs to continue occupying the land—could be construed as an affirmation of the plaintiffs’ ownership rights.
• Whether acts of possession by mere tolerance can amount to possession sufficient for a claim under adverse possession or prescription when a formal registration has taken place.

Procedural Error on the Amended Complaint

• Whether the trial court erred in refusing to admit the amended complaint, thereby precluding additional arguments regarding due process and the timing of plaintiffs’ discovery.

Ruling:

• (Subscriber-Only)

Ratio:

• (Subscriber-Only)

Doctrine:

• (Subscriber-Only)