Title
Arriola y Cabrera vs. De La Serna
Case
G.R. No. 5397
Decision Date
Dec 17, 1909
Dispute over Manila land ownership: plaintiff claims inheritance from mother, defendant asserts prescriptive title via husband’s possession; court ruled for defendant due to good faith and 10+ years of uninterrupted possession.

Case Digest (G.R. No. L-1802)
Expanded Legal Reasoning Model

Facts:

  • Parties and Nature of Action
    • The plaintiff, Fabiana Arriola y Cabrera, acts as the administratrix of the estate of her late mother, Simona Cabrera, and brings an action of ejectment for recovery of a parcel of land.
    • The defendant, Carolina Gomez de la Serna, asserts her ownership and that of her minor children, based on inheritance from her deceased husband, Jose M. Perez Rubio, and a contract of distribution among his heirs.
  • Description of the Property and Possession History
    • The property in dispute is situated in the city of Manila, at the corner of Calles San Luis and Nueva.
    • The plaintiff relies on witness testimony that her mother possessed the land until approximately 1882, after which an order from the court ousted her, transferring possession to Jose M. Perez Rubio.
  • Title and Conveyancing
    • Jose M. Perez Rubio is shown to have acquired title by a conveyance executed by the Court of Quiapo on December 21, 1881.
    • Following the conveyance, Rubio took immediate possession of the property, a possession that continued uninterrupted and publicly under claim of ownership up to the commencement of this action.
  • Allegations of Defective Possession and Title
    • The plaintiff contends that Rubio’s possession was not in good faith, citing that after the conveyance, an opponent of Rubio sought a rehearing that led to the suspension of the court order which underpinned said conveyance.
    • It was argued that because the order was effectively annulled by suspension and the case reopened, Rubio’s title could be considered flawed, and his continued possession might be tainted by bad faith, especially given his professional background as a lawyer.
  • Defendant’s Counter and Basis for Claim
    • The defendant, however, bases her claim not solely on her husband’s possession but on her own personal occupancy and possession of the land since February 15, 1896.
    • Her possession has been characterized as public, peaceful, uninterrupted, and in good faith, under a proper title obtained through inheritance and the recognized contract of distribution among Rubio’s heirs.

Issues:

  • Question of Good Faith Possession
    • Was the possession of the land by Jose M. Perez Rubio tainted by bad faith due to the alleged suspension and reopening of the case affecting his original title?
    • Did any alleged defects in Rubio’s title automatically tarnish the good faith possession of the defendant who inherited the land?
  • Effect of Inheritance on Possession
    • Can the defendant’s uninterrupted possession and personal occupancy of the property for more than 10 years, under good faith and with what is considered a proper title, overcome any potential defects in her husband’s title?
    • Is the inheritance sufficient to protect the defendant from any imputed bad faith associated with the actions of her husband?
  • Application of Prescription
    • Does the defendant’s possession meet the requirements of prescription under Article 1957 of the Civil Code, which calls for 10 years of possession with good faith and proper title?
    • Does the uninterrupted nature of her occupancy from February 15, 1896, until the filing of the action on October 17, 1908, legally establish ownership of the land?

Ruling:

  • (Subscriber-Only)

Ratio:

  • (Subscriber-Only)

Doctrine:

  • (Subscriber-Only)

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