Case Digest (G.R. No. 184109) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
This case involves petitioner Celerino E. Mercado and respondents Belen Espinocilla and Ferdinand Espinocilla concerning disputes over ownership and possession of portions of Lot No. 552, a parcel of land located at Magsaysay Avenue, Zone 5, Bulan, Sorsogon. The land initially belonged to Doroteo Espinocilla and measured 570 square meters. Upon Doroteo's death, his five children—Salvacion, Aspren, Isabel, Macario, and Dionisia—equally divided the land, each inheriting 114 square meters. Dionisia died without issue, and Macario took possession of her share, claiming a donation in his favor evidenced by a 1948 affidavit. Macario and his daughters later sold a portion of the land to Roger Espinocilla, who subsequently sold part of it to Caridad Atienza. Petitioner, as the son of Salvacion, sought to recover possession of 39 square meters he alleged were encroached upon by respondents. The trial court ruled in favor of petitioner partially nullifying Macario's sale and ordering part Case Digest (G.R. No. 184109) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
# Ownership and Division of Lot No. 552
- Doroteo Espinocilla owned a parcel of land, Lot No. 552, with an area of 570 sq. m., located in Bulan, Sorsogon.
- Upon Doroteo's death, his five children—Salvacion, Aspren, Isabel, Macario, and Dionisia—divided Lot No. 552 equally among themselves.
- Dionisia died without issue, and Macario took possession of her share, claiming in a 1948 affidavit that Dionisia had donated her share to him in May 1945.
# Subsequent Transactions
- On August 9, 1977, Macario and his daughters sold 225 sq. m. of the lot to his son Roger Espinocilla, husband of respondent Belen Espinocilla and father of respondent Ferdinand Espinocilla.
- On March 8, 1985, Roger sold 114 sq. m. to Caridad Atienza.
- A survey revealed that Belen Espinocilla occupies 109 sq. m., Caridad Atienza occupies 120 sq. m., Caroline Yu occupies 209 sq. m., and petitioner Celerino Mercado (Salvacion's son) occupies 132 sq. m.
# Petitioner’s Claim
- Petitioner claimed ownership of 171 sq. m., consisting of 142.5 sq. m. inherited from his mother Salvacion and 28.5 sq. m. purchased from his aunt Aspren.
- He alleged that respondents encroached on 39 sq. m. of his share, as he only occupies 132 sq. m.
# Respondents’ Defense
- Respondents argued that Macario’s share increased when he received Dionisia’s share, which was later sold to Roger.
- They claimed rightful possession through acquisitive prescription and denied any encroachment.
Issues:
- Whether petitioner’s action to recover the 39 sq. m. portion is barred by prescription.
- Whether Macario’s acquisition of Dionisia’s share was valid and whether his possession was adverse and uninterrupted.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Conclusion:
The Supreme Court denied petitioner’s appeal, ruling that respondents’ possession of the disputed portion was acquired through extraordinary acquisitive prescription and that petitioner’s action was barred by extinctive prescription. The Court emphasized the importance of timely action in property disputes and upheld the finality of adverse possession after the lapse of the prescriptive period.
- On August 9, 1977, Macario and his daughters sold 225 sq. m. of the lot to his son Roger Espinocilla, husband of respondent Belen Espinocilla and father of respondent Ferdinand Espinocilla.
- On March 8, 1985, Roger sold 114 sq. m. to Caridad Atienza.
- A survey revealed that Belen Espinocilla occupies 109 sq. m., Caridad Atienza occupies 120 sq. m., Caroline Yu occupies 209 sq. m., and petitioner Celerino Mercado (Salvacion's son) occupies 132 sq. m.
# Petitioner’s Claim
- Petitioner claimed ownership of 171 sq. m., consisting of 142.5 sq. m. inherited from his mother Salvacion and 28.5 sq. m. purchased from his aunt Aspren.
- He alleged that respondents encroached on 39 sq. m. of his share, as he only occupies 132 sq. m.
# Respondents’ Defense
- Respondents argued that Macario’s share increased when he received Dionisia’s share, which was later sold to Roger.
- They claimed rightful possession through acquisitive prescription and denied any encroachment.
Issues:
- Whether petitioner’s action to recover the 39 sq. m. portion is barred by prescription.
- Whether Macario’s acquisition of Dionisia’s share was valid and whether his possession was adverse and uninterrupted.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Conclusion:
The Supreme Court denied petitioner’s appeal, ruling that respondents’ possession of the disputed portion was acquired through extraordinary acquisitive prescription and that petitioner’s action was barred by extinctive prescription. The Court emphasized the importance of timely action in property disputes and upheld the finality of adverse possession after the lapse of the prescriptive period.
- Respondents argued that Macario’s share increased when he received Dionisia’s share, which was later sold to Roger.
- They claimed rightful possession through acquisitive prescription and denied any encroachment.
Issues:
- Whether petitioner’s action to recover the 39 sq. m. portion is barred by prescription.
- Whether Macario’s acquisition of Dionisia’s share was valid and whether his possession was adverse and uninterrupted.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)