Title
Merchant vs. City of Manila
Case
G.R. No. 3818
Decision Date
Aug 19, 1908
Edward Merchant sought land registration for three tracts in Manila; ownership disputes arose with Luis Dumas, the City of Manila, and Natalia Eloriaga. Dumas' title to Parcel No. 1 was upheld, while Merchant's claims to Parcels No. 2 and 3 were partially affirmed, with improvements on Parcel No. 3 requiring resolution.
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Case Digest (G.R. No. 3818)

Facts:

  1. Petition for Land Registration: On April 13, 1904, Edward B. Merchant filed a petition with the Court of Land Registration, seeking to be inscribed as the owner of three tracts of land in Tanduay, Manila, excluding the buildings on the land. The petition was denied for the first and third tracts, as well as for part of the second tract occupied by Natalia Eloriaga. Merchant appealed the adverse judgment.

  2. Opposition to Parcel No. 1: Luis Elzingre Dumas opposed Merchant's claim to the first tract, asserting ownership through a purchase from Amanda de Marcaida. The court ruled in favor of Dumas, finding that his title deeds proved ownership of the land described as Parcel No. 1 in Merchant's petition. Merchant contested this, arguing that the land described in Dumas' deeds was different and that the documents were insufficient to prove ownership.

  3. Identity of the Land: Merchant admitted in a June 11, 1904, motion that the land described in Dumas' deeds was the same as Parcel No. 1 in his petition. Evidence showed that the land was bounded by the Philippine Lumber Development Company's property, which was acquired from Veloso, Merchant's grantor. Veloso's deed described the land as bounded by Amanda de Marcaida's property, further confirming the identity of the land.

  4. Title of Dumas: Dumas' title was traced back to a sale by Santiago Naguit to Antonio de Marcaida in 1889, with a right of repurchase that was never exercised. The property was registered in Antonio de Marcaida's name in 1895, and Dumas acquired it from Marcaida's heirs in 1902. The court found Dumas' title valid under the Mortgage Law.

  5. Opposition by the City of Manila: The City of Manila opposed Merchant's claim to Parcel No. 1, arguing that it included part of an estero (waterway). The court did not address this issue, as the petition for Parcel No. 1 was dismissed.

  6. Parcel No. 3 and Prescription: The Pacific Oriental Trading Company opposed Merchant's claim to the third tract, asserting ownership by prescription. The court found that Merchant's documents, previously upheld by the Supreme Court of Spain and the Philippine Supreme Court, established prima facie ownership of the land. The defendant failed to prove possession since 1874, as required for prescription.

  7. Improvements on Parcel No. 3: Merchant sought to register the land without the buildings, but later amended his petition to include the buildings. The defendant claimed good faith in making improvements worth over P90,000. The court held that the improvements were made with the knowledge of Merchant's grantor, Veloso, and without objection, implying good faith on both sides. The court ruled that the land, encumbered by the improvements, could not be registered until the parties resolved the issue of the improvements' value.

  8. Parcel No. 2 and Natalia Eloriaga: The court denied Merchant's petition for the part of the second tract occupied by Natalia Eloriaga, finding that Merchant had not proven ownership. However, the court reversed this decision, holding that Merchant's documents established prima facie ownership of the land.

Issue:

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Ruling:

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Ratio:

  1. Identity of the Land: Merchant's admission in his June 11, 1904, motion and the evidence of boundary descriptions established that the land in Dumas' deeds was the same as Parcel No. 1 in Merchant's petition.
  2. Validity of Dumas' Title: Dumas' title, derived from a valid sale and registration under the Mortgage Law, was sufficient to prove ownership.
  3. Prescription: The defendant failed to prove possession of Parcel No. 3 since 1874, as required for extraordinary prescription. Veloso's prior possession, established through judicial proceedings, interrupted any prescription in favor of the defendant's alleged grantors.
  4. Good Faith and Improvements: The improvements on Parcel No. 3 were made with the knowledge of Merchant's grantor, Veloso, and without objection, implying good faith on both sides. The land could not be registered while encumbered by the improvements, and the parties were required to resolve the issue of the improvements' value.
  5. Prima Facie Ownership: Merchant's documents, previously upheld by the Supreme Court of Spain and the Philippine Supreme Court, established prima facie ownership of the land in question.


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