G.R. No. 19190 - People vs. Concepcion

Aniceto Lacson, as petitioner and appellant, sought the inscription in the property registry of the Island of Sicogon, situated within the territorial limits of the municipality of Balasan, Iloilo.
The opposition to his claim came from the Director of Lands, the Director of Forestry, the municipality of Balasan, and several island residents, though the municipality and residents later withdrew their opposition through negotiated agreements.

The petitioner claimed that the Island of Sicogon had originally been ceded to Ynchausti & Co. by the Spanish government through a composition title, allegedly issued in 1887.
Ynchausti & Co. purportedly sold the island to Ramon Fontanet around 1890 or 1891.
Fontanet, facing financial distress and later becoming a victim of revolutionary violence, transferred his rights – including the island and a herd of cattle – to Lacson in payment of a debt, as evidenced by a document marked Exhibit B.
The petitioner's claim was supported by testimonies asserting that his predecessors, through possession, had enjoyed the island openly, continuously, and adversely for more than the ten-year statutory period required.

The petitioner's inability to present the composition title from the Spanish regime was explained by extensive destruction caused by fires during the revolution.
The residence of Ramon Fontanet and several government archives, including those of the provincial government of Iloilo and a Manila forestry office, had been burned.
The absence of the original document was thus attributed to these historical events, a circumstance neither impugned nor contradicted by the opponents.

Multiple witnesses, including Arturo Barcelo, Bernardino Sison, Victor Amistoso, Nicolas Roces, and Fernanda Ontaneres, provided key testimony.
Witnesses affirmed that Ynchausti & Co. possessed the island in good faith and that this possession continued through successive management (from agents of Ynchausti & Co. to Ramon Fontanet and eventually to Lacson).
Testimony detailed that:

The possession by these parties was both quiet and adverse, in alignment with the requirements for acquiring ownership by prescription.
Even when agricultural development was incomplete and portions were merely forested, such conditions did not negate the petitioner's claim of rightful ownership of the agricultural lands.

The withdrawal of opposition by the municipality of Balasan underscored a de facto acknowledgment of Lacson’s rights, further cementing his claim.

The municipality of Balasan agreed to withdraw its opposition on conditions that a portion of the land be allocated for public purposes (a public square, a cemetery, a school lot, and maintenance of municipal streets).
Similarly, several residents in the island, through negotiations by their counsel, also withdrew their oppositions against the petitioner's claim.

Whether the Island of Sicogon was indeed ceded by the Spanish government to Ynchausti & Co., thereby conferring upon the firm an absolute title to the property.

In the absence of conclusive documentary evidence of the composition title, whether the continuous, exclusive, and adverse possession exercised by the petitioner's predecessors (Ynchausti & Co. and Ramon Fontanet) and by Lacson himself for a period exceeding ten years qualifies him for inscription in the property registry under the applicable law.