Title
Atienza vs. Manaloto
Case
G.R. No. 28896
Decision Date
Oct 10, 1928
Jose Atienza sought land registration, claiming inheritance from his mother. Oppositors contested joint ownership, but the court ruled in his favor, affirming his exclusive possession and ownership based on evidence and prescription.
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Case Digest (G.R. No. 28896)

Facts:

    Application for Land Registration

    • Jose Atienza applied for the registration of lands described in plans A and B attached to his application.
    • He asserted that he had inherited these lands from his deceased mother, Paula Medina.
    • The applicant further claimed that both he and his predecessors in interest had enjoyed quiet, peaceful, and uninterrupted possession of the lands for more than sixty years, which is the period required for acquiring ownership through prescription.

    Opposition to the Registration

    • The Director of Lands, on behalf of the Insular Government, entered opposition regarding certain parcels.
    • The opposition pertained to two specific parcels on plan Psu-31380, identified as Exhibit A.
    • Private oppositors also filed their opposition on behalf of:
    • Venancio Samson, representing interests of Dominga Manaloto;
    • Tomas Morales, Guadalupe Manaloto, Candelaria Manaloto (as descendants or related parties); and
    • Enriqueta Manaloto on behalf of her husband, Agustin Basco.
    • The private oppositors’ claim was based on the allegation that the land in question was owned in common (pro indiviso) between the applicant and themselves as descendants of Juana Medina.

    Narrowing of the Opposition

    • During the proceedings, the Director of Lands, represented by the provincial fiscal, withdrew his opposition with respect to the two parcels on plan Psu-31551 (Exhibit B).
    • Consequently, the remaining opposition focused solely on the two parcels of land shown on plan Psu-31380.

    Evidence Presented by the Parties

    • Evidence from the Applicant’s Side
    • Documentary and oral evidence demonstrated that the two parcels on plan Psu-31380 were originally acquired, at least in part, by his mother, Paula Medina.
    • Additional evidence showed that the remaining portion of the land was obtained by Paula Medina during her marriage to Agripino Atienza.
    • After the death of Paula Medina, during the partition of her estate, the parcels were adjudicated to the applicant by his father, as both his legitime share and an advance on his inheritance.
    • The applicant also maintained that from the time he took possession of the land, he had exclusively derived income from these parcels, as had his predecessors by long and adverse possession consistent with prescription requirements.
    • Evidence from the Oppositors’ Side
    • The oppositors presented evidence to show their descent from Juana Medina, mother of Paula Medina.
    • They highlighted that Paula Medina had a sister, Juliana Sumira, who was the mother of the oppositors (the Manaloto family).
    • Their claim rested on an alleged joint ownership of the land between the applicant and themselves.
    • It was further alleged that the oppositors participated in the harvest of the lands (yielding about 10 to 20 cavans of unhulled rice annually).
    • One witness supporting the oppositors indicated, however, in his own registration application, that the adjacent property belonged solely to the applicant.

    Lower Court Decision

    • After examining the totality of the evidence, the trial court ruled in favor of the applicant.
    • The court found that the weight of evidence supported the applicant’s claim of exclusive and continuous possession.
    • The oppositors’ participation in the harvest of the vast parcel was deemed preposterous by the trial judge, specifically pointing to the improbability of the limited harvest yields claimed.
    • The trial court dismissed the opposition concerning the two parcels on plan Psu-31380 and ordered the adjudication and registration of all four parcels in the applicant’s name (noting his 52 years of age).

    Grounds for Appeal Raised by the Oppositors

    • Assertion that the lower court erred in not establishing that the land originally belonged to Juana Medina (mother of Paula Medina) and, upon her death, passed to Paula Medina and Juliana Sumira.
    • Argument that the court should have determined that the contested parcels belonged to the applicant and the oppositors jointly, and that such joint ownership was still in effect.
    • Claim that dismissal of their opposition and denial of a motion for a new trial constituted an error.

    Final Outcome

    • The appellate court held that the issues raised by the oppositors were purely questions of fact and pertained to the appreciation of evidence.
    • Citing precedents (such as U. S. vs. Pico, U. S. vs. Benitez and Lipia, and U. S. vs. Melad), the court affirmed the fact findings of the trial court.
    • The judgment was ultimately affirmed, and the applicant’s possession and ownership of the lands were upheld with costs against the appellants.

Issue:

    Whether the two parcels of land on plan Psu-31380, originally acquired by Paula Medina, should be deemed to belong to the applicant alone or to be jointly owned (pro indiviso) by the applicant and the oppositors as descendants of Juana Medina.

    • Consideration of the genealogical relationship between the parties, particularly the connection between Juana Medina, Paula Medina, and the oppositors.
    • Evaluation of evidence regarding the partition of the estate and the subsequent adjudication of the land to Jose Atienza.

    Whether the trial court erred in dismissing the oppositors’ claim and in denying their motion for a new trial.

    • Examination of whether any material facts were overlooked or misapprehended by the trial court in reaching its decision.
    • Assessment of the credibility and weight of the evidence presented by both sides regarding long and uninterrupted possession.
  • Whether the evidence, on its face, supports the sole ownership of the land by the applicant or justifies a finding of joint ownership with the oppositors.

Ruling:

  • (Subscriber-Only)

Ratio:

  • (Subscriber-Only)

Doctrine:

  • (Subscriber-Only)

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