Case Digest (G.R. No. L-54901) Core Legal Reasoning Model
Facts:
The case at hand involves the Heirs of Quirico Seraspi and Purificacion R. Seraspi as petitioners against the Court of Appeals and Simeon Recasa as respondents. The decision was rendered on April 28, 2000, by the Second Division of the Supreme Court of the Philippines. The controversy centers on the ownership and possession of two parcels of land situated in Barangay Lapnag, Banga, Aklan. Marcelino Recasa was the original owner of these parcels, which were distinctly identified: Parcel I, a 770-square meter cocal land under Tax Declaration No. 3721, Series of 1984, and Parcel II, a 3,648-square meter cocal land under Tax Declaration No. 11079. Marcelino Recasa had three marriages and fifteen children at the time of his passing in 1943. In 1948, his heirs partitioned the intestate estate into three parts corresponding to the shares due to the heirs of each marriage. Following the partition, in the same year, Patronicio Recasa sold the share of the heirs of the first marriage to
Case Digest (G.R. No. L-54901) Expanded Legal Reasoning Model
Facts:
- Ownership and Property Description
- Marcelino Recasa was owner of two parcels of land in Banga, Aklan:
- PARCEL I – A 770-square-meter cocal land located at Barangay Lapnag, bounded by Lazaro Navarra (north), Celsa Retis (south), Banga-Libacao Provincial Road (east), and Aklan River (west).
- PARCEL II – A 3,648-square-meter cocal land in Barangay Lapnag, bounded by Concepcion Navarra (north), Diosdado Navarra (south), Gabriel Reloj (east), and the National Road (west).
- Tax declarations:
- Parcel I was declared under Tax Declaration No. 3721, Series of 1984, with an assessed value of P2,440.00.
- Parcel II was declared under Tax Declaration No. 11079, Series of 1984, with an assessed value of P1,650.00, and was in the name of Purificacion Seraspi.
- Family Background and Estate Partition
- Marcelino Recasa contracted three marriages and had fifteen children from these unions.
- Upon his death in 1943, his intestate estate was partitioned in 1948 into three shares corresponding to each marriage.
- The partition led to subsequent sales:
- Patronicio Recasa (representing the heirs of the first marriage) sold his share to Dominador Recasa (an heir of the second marriage).
- On June 15, 1950, Dominador sold the share to Quirico and Purificacion Seraspi, whose heirs are the current petitioners; this sale included the property originally sold by Patronicio.
- Mortgage, Foreclosure, and Subsequent Administration
- In 1958, the Seraspis obtained a loan from Kalibo Rural Bank, Inc. (KRBI) using the lands as security for improvements.
- Failure to pay the loan led to the foreclosure of the mortgage, and KRBI sold the lands as the highest bidder.
- KRBI subsequently sold the lands to Manuel Rata, who was the brother-in-law of Quirico Seraspi.
- Despite the change in title, Quirico Seraspi was allowed to administer the property.
- Possession Dispute and Recovery Action
- In 1974, private respondent Simeon Recasa, child of Marcelino from his third marriage, capitalized on Quirico Seraspi’s illness (due to a stroke) and forcibly took possession of the lands.
- In 1983, the Seraspis purchased the property from Manuel Rata and later filed a complaint against Simeon Recasa for recovery of possession and ownership.
- Procedural History
- The trial court ruled in favor of the Seraspis, holding that they acquired the property both through sale and by acquisitive prescription.
- The Court of Appeals reversed the trial court’s decision, dismissing the complaint on the ground that the action was barred by prescription.
- The petition was subsequently filed by the heirs of Quirico Seraspi (after Quirico’s death) against Simeon Recasa.
Issues:
- Whether the petitioners' action for recovery is barred by extinctive prescription.
- Consideration of the timely filing of the recovery action (filed in 1987, thirteen years after the alleged deprivation of possession).
- Analysis of whether the period applicable (thirty years for real actions over immovables) affects the petitioners’ claim.
- Whether private respondent Simeon Recasa acquired ownership of the properties through acquisitive prescription.
- Examination of the requirements of ordinary acquisitive prescription, specifically the elements of just title and good faith.
- Evaluation of whether Simeon Recasa’s entry into the property qualifies as adverse possession under the standards set by the Civil Code.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)