G.R. No. L-8029 - Espique vs. Espique

Plaintiffs: Emilia Espique and Santiago Espique, who claim common and pro indiviso ownership of three parcels of land.
Defendant: Jacinto Espique, who is asserted to have acquired title through donation propter nuptias from his predecessors.
Property Location: The disputed lands are situated in Tayug, Pangasinan.

They seek a partition of the three parcels of land.
They also claim damages for unenjoyed profits from the year 1916 to 1949 (a period of 33 years).

The defendant asserts that the properties were donated to him and his wife by his parents, Basilio Espique and Maria Diaz, as well as by his grandfather, Julian Espique, on May 8, 1906.
He maintains that since the donation, he and his wife have possessed and enjoyed the lands adversely and continuously for over 40 years, thereby baring the partition action by prescription.

All are legitimate children of Basilio Espique and Maria Diaz, with the plaintiff being descendants and defendant being the beneficiary through his lineage.
The land in question was donated propter nuptias by Julian Espique to the spouses Basilio Espique and Maria Diaz, and in favor of Jacinto Espique and Victorina Abenojar in a private document dated May 8, 1906.

The stipulation of facts essentially clarified the chain of title and the nature of possession by the defendant.

Filed a motion to dismiss based on the allegation that the plaintiff’s complaint lacked cause of action.
Relied on the defense of prescription and the absence of a valid donation deed executed in a public instrument.

The trial court noted that the defendant had possessed the land adversely and continuously for more than 30 years based on admissions in the pleadings.
It ruled that the donation, though invalid as a transfer of title due to not being executed in a public document, served as the factual basis for adverse possession via acquisitive prescription.
Consequently, the action for partition was dismissed without pronouncement as to costs.

Plaintiffs appealed the decision, contending that there was no evidence of adverse possession for the requisite period.
The Court of Appeals certified the case to the Supreme Court because it raised pure questions of law regarding prescription and the validity of the donation.

Whether the lower court erred in dismissing the complaint by finding that it lacked cause of action.

This involves assessing if the allegations and admissions sufficiently established the defendant’s claim of acquisitive prescription.

Whether the defendant’s possession of the property—characterized as open, adverse, and continuous for over 30 years—adequately fulfilled the elements for acquisitive prescription.
Whether the verbal donation, although invalid as a transfer of title under the requirements of Article 633 of the old Civil Code and Article 1328 (regarding gifts propter nuptias), could still be the basis for establishing adverse possession.
Whether plaintiffs were precluded from presenting additional evidence to refute the defendant’s claim, considering their own admissions in the complaint and the stipulation of facts.