Case Digest (G.R. No. 2539)
Facts:
On February 23, 1894, Vicente Balpiedad filed a petition with the Court of Land Registration to be recognized as the owner of a parcel of land measuring 13,225 square meters located in a government reservation in Baguio, Benguet Province. This land was also a subject of a prior petition in the case of Cristobal Ramos vs. The Insular Government. The Solicitor-General contested Balpiedad's petition, arguing that the land in question was public property. However, the lower court ruled in favor of Balpiedad, ordering the inscription of the land in his name. After this decision, the Solicitor-General sought a new trial, but this motion was denied, leading to the Solicitor-General appealing by way of a bill of exceptions.
The legal issues hinged on the adverse possession of the land. On November 26, 1901, Balpiedad purchased the parcel in question from an Igorot named Pokay, who had obtained it from his deceased father, Ampagney. Ampagney, in turn, acquired the land from his own
Case Digest (G.R. No. 2539)
Facts:
- On February 23, 1894, Vicente Balpiedad filed a petition before the Court of Land Registration.
- The petition sought the inscription of a 13,225-square-meter tract of land as his own, located in the Government reservation at Baguio, in the Province of Benguet.
- The land in question was part of a larger area previously described in the petition of Cristobal Ramos vs. The Insular Government.
Petition and Initial Proceedings
- The Solicitor-General appeared in the lower court, contesting the petition on the ground that the lands were public lands.
- Despite the opposition, the trial court granted the petitioner's prayer and ordered the inscription of the land in Vicente Balpiedad's name.
- The Solicitor-General moved for a new trial, which was denied, prompting him to bring the case to the higher court by bill of exceptions.
Opposition and Lower Court Decision
- On November 26, 1901, Vicente Balpiedad purchased the land from an Igorot named Pokay.
- An instrument of sale was executed on January 11, 1902, and duly recorded in the Registry of Property at San Fernando.
- Pokay had acquired the land from his deceased father, who in turn had inherited it from Pokay’s grandfather, demonstrating a lineage of possession.
- Historical evidence shows that the land was cultivated by the grandfather, the father, and later by Pokay himself, with the presence of a house that was initially erected, later destroyed, and then replaced (the new house subsequently destroyed by fire).
Purchase and Possession History
- The petition centered on whether Vicente Balpiedad had established an adverse possession of the land for the required ten-year period.
- Evidence indicated that there was continuous and uncontested possession by Pokay and his predecessors, from before the survey through its conduct and afterward.
- Although conflicting testimony emerged regarding whether a survey (related to the Ramos case) interrupted possession, the majority of the evidence supported the continuity of possession.
- It was concluded that the survey, rather than interrupting possession, did not stop the running of the statute of limitations.
Evidence of Adverse Possession
- The case was evaluated under Section 41 of the Code of Civil Procedure, as applied by Acts Nos. 648 and 627.
- The evidence on record satisfied the statutory requirements for adverse possession, thereby affirming the petitioner's claim.
Legal Framework
Issue:
- Whether Vicente Balpiedad, through acquiring the land from Pokay and the subsequent continuous possession, met the statutory requirement of adverse possession for a period of ten years.
- Whether the occurrence of the survey during the period of possession constitutes an interruption sufficient to defeat the adverse possession claim.
Adverse Possession Requirement
- Whether the legal reasoning in the present case aligns with that previously presented in Jones vs. The Insular Government, despite differences concerning the native status of the petitioner.
- The issue of whether any procedural or evidentiary discrepancies affected the ultimate factual issue regarding adverse possession.
Comparative Legal Context
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)