Title
Arroyo vs. Yulo
Case
G.R. No. L-5740
Decision Date
Jan 7, 1911
Plaintiff Ignacio Arroyo proved ownership of disputed land through 30+ years of possession; defendants unlawfully built a warehouse on it, causing damages. Court upheld plaintiff's claim, awarded damages and rent.
Font Size:

Case Digest (G.R. No. L-5740)

Facts:

Ownership and Possession of the Land

  1. The plaintiff, Ignacio Arroyo, claimed ownership of a parcel of urban property in Molo, Iloilo, consisting of a house and lot. The property was described in detail in the complaint.
  2. The plaintiff alleged that the defendants, Carmen Yulo and her husband Sabas Locsin, owned an adjoining lot to the north. On this lot, the defendants constructed a temporary warehouse (camarin) made of old galvanized iron, which encroached on the plaintiff's land by approximately 90 square varas.
  3. Despite demands from the plaintiff to vacate the land and remove the warehouse, the defendants refused, claiming ownership over the disputed portion.

Defendants' Counterclaim

  1. The defendants denied the plaintiff's allegations and filed a cross-complaint, asserting that the land in question was part of an undivided estate in which they had an equal share. They sought partition of the property.

Trial Court Findings

  1. The Court of First Instance of Iloilo found that:

    • The original owner of the land was Liboro Ramiro (alias Bonga), whose heirs transferred ownership to the plaintiff.
    • The plaintiff and his predecessors had possessed the land openly, notoriously, and publicly for over 30 years.
    • The defendants constructed the warehouse on the plaintiff's land about eight or nine years prior to the suit.
    • The warehouse was located within the plaintiff's property, as indicated in the court's rough sketch (Exhibit B).
    • The defendants refused to remove the warehouse despite demands and claimed ownership of the land.
    • The warehouse's roof caused water damage to the plaintiff's house, resulting in P100 in damages.
    • The reasonable rental value for the illegally occupied land was P2 per month, totaling P192 for eight years.
  2. The trial court ruled in favor of the plaintiff, awarding him ownership and possession of the land, damages of P292, and costs against the defendants.

Appeal

  1. The defendants appealed the decision and moved for a new trial, which was denied. They filed a bill of exceptions with the Supreme Court, assigning five errors. However, they failed to take exception to the denial of their motion for a new trial, limiting the Supreme Court's review to questions of law.

Issue:

  • (Unlock)

Ruling:

  • (Unlock)

Ratio:

  1. Ownership and Possession: Ownership of land is established through open, continuous, and notorious possession for the required period under the law. The plaintiff and his predecessors had possessed the land for over 30 years, satisfying the requirements for ownership.
  2. Unlawful Occupation: The defendants' construction of the warehouse on the plaintiff's land constituted unlawful occupation, and their refusal to vacate despite demands reinforced their liability.
  3. Limitations on Appellate Review: Under Section 497, paragraph 3, of the Code of Civil Procedure, the Supreme Court cannot review the evidence if the appellant fails to take exception to the denial of a motion for a new trial. The court must accept the trial court's findings of fact and limit its review to questions of law.
  4. Damages and Rental Payments: The defendants are liable for damages caused by their unlawful occupation, including physical damage to the plaintiff's property and reasonable rental payments for the use of the land.


Jur is an AI-powered legal research platform in the Philippines for case digests, summaries, and jurisprudence. AI-generated content may contain inaccuracies; please verify independently.