Case Digest (G.R. No. L-8018)
Facts:
The case of Gil Atun, et al. vs. Eusebio Nunez, et al. (G.R. No. L-8018) was decided on October 26, 1955. The plaintiffs-appellants, Gil Atun, Camila Atun, and Dorotea Atun, filed a complaint for the recovery of a parcel of registered land located in Legaspi City, which was registered under Original Certificate of Title No. 11696 in the name of their deceased aunt, Estefania Atun. The complaint was initiated on August 7, 1950. The plaintiffs claimed that they inherited the land from Estefania, who died without any issue. They had possessed the land from 1927 until 1930, when Gil Atun delivered it to Silvestra Nunez, the sister of defendant-appellee Eusebio Nunez, for cultivation. Silvestra paid the Atuns a portion of the harvest as rental. In 1940, Silvestra transferred the land to Eusebio Nunez, who subsequently refused to acknowledge the plaintiffs' ownership and failed to deliver their share of the produce. Eusebio Nunez later sold the land to co-defendant Diego Belg...
Case Digest (G.R. No. L-8018)
Facts:
Parties Involved:
- Plaintiffs-Appellants: Gil Atun, Camila Atun, and Dorotea Atun.
- Defendants-Appellees: Eusebio Nunez and Diego Belga.
Subject Matter:
- The case involves a parcel of registered land located in Legaspi City, Albay, covered by Original Certificate of Title No. 11696 in the name of Estefania Atun, the deceased aunt of the plaintiffs.
Background:
- Estefania Atun, the registered owner, died without issue, and the plaintiffs inherited the land as her legal heirs.
- From 1927 to 1930, the plaintiffs possessed the land. In 1930, plaintiff Gil Atun delivered the land to Silvestra Nunez (sister of defendant Eusebio Nunez) for cultivation, with Silvestra paying a portion of the harvest as rental.
- In 1940, Silvestra Nunez turned over the land to Eusebio Nunez, who subsequently refused to recognize the plaintiffs' ownership or deliver their share of the produce.
- Eusebio Nunez later sold the land to Diego Belga, who took possession with knowledge that the land belonged to the plaintiffs.
Legal Proceedings:
- The plaintiffs filed a complaint for recovery of the land on August 7, 1950.
- After the plaintiffs presented their evidence, the defendants filed a demurrer to the evidence, arguing that the plaintiffs' action had prescribed under Section 40 of Act No. 190 (Code of Civil Procedure).
- The trial court dismissed the complaint, ruling that the 10-year prescriptive period for filing an action for recovery had elapsed (starting from 1940 when plaintiffs lost possession) and that the plaintiffs failed to prove their ownership.
Appeal:
- The plaintiffs appealed to the Court of Appeals, which forwarded the case to the Supreme Court due to the legal question involved.
Issue:
Primary Issue:
- Whether the trial court erred in dismissing the plaintiffs' complaint on the ground of prescription of action.
Subsidiary Issue:
- Whether the plaintiffs sufficiently proved their ownership of the land to overcome the presumption of lawful ownership in favor of the defendants as possessors.
Ruling:
On Prescription:
- The Supreme Court held that the trial court erred in dismissing the complaint on the ground of prescription.
- Under Section 40 of Act No. 496 (Land Registration Act), no title to registered land can be acquired by prescription or adverse possession in derogation of the registered owner's title.
- The Court emphasized that the right of a registered owner to recover possession of registered property is imprescriptible, as possession is a mere incident of ownership.
On Ownership:
- The Court ruled that the plaintiffs, as the legal heirs of Estefania Atun, had a valid claim to the land.
- The land remained registered in Estefania Atun's name, and the plaintiffs, as her heirs, stepped into her rights by operation of law.
- The trial court erred in holding that the plaintiffs failed to prove their ownership, as the Torrens title in Estefania Atun's name was sufficient evidence of ownership.
On Damages:
- The Court awarded the plaintiffs P500 in damages, as supported by their evidence.
Final Judgment:
- The Supreme Court reversed the trial court's order of dismissal.
- The plaintiffs were declared the lawful owners of the land, and the defendants were ordered to surrender possession and pay damages.
Ratio:
- (Unlock)