Title
Rivera vs. Roman Catholic Archbishop of Manila
Case
G.R. No. 14594
Decision Date
Jan 29, 1920
Plaintiffs claimed good faith possession of land, sought compensation for fish ponds; Supreme Court ruled against them, upholding defendant's ownership.
A

Case Digest (G.R. No. 14594)

Facts:

Eduardo Rivera, Anacleto Aguinaldo, Rufino Salaw, Jacinto Sison, Eleuterio De La Cruz, Quiterio Victorino and Agueda De La Cruz v. The Roman Catholic Archbishop of Manila, G.R. No. 14594, January 29, 1920, the Supreme Court En Banc, Torres, J., writing for the Court.

The plaintiffs (collectively) filed a complaint in the Court of First Instance of Rizal on February 2, 1916, alleging they had been in good-faith possession of certain parcels of the estate called Hacienda de Sta. Clara in Malabon, Rizal, and that they had constructed and enjoyed several fish ponds on those lands. They alleged that the defendant, The Roman Catholic Archbishop of Manila (hereafter “the defendant entity”), had been declared absolute owner of the Hacienda in an earlier registration action decided by this Court on August 5, 1915 (Registration Case No. 8719), and sought (a) indemnity for the value of the fish ponds and (b) the right to retain the portions of land occupied by them until fully paid.

The defendant demurred (overruled), answered generally denying material averments, obtained from plaintiffs a bill of particulars, and later filed an amended answer asserting, among other defenses, res judicata and the plaintiffs’ bad faith; it also counterclaimed for P75,000 as rents/canon allegedly due for many years’ occupation. The trial court, after hearing evidence, rendered judgment absolving the defendant from the plaintiffs’ complaint and absolving the plaintiffs from the defendant’s counterclaim; no cost findings were made. Plaintiffs’ motion for a new trial was denied and they took a direct appeal by bill of exceptions to this Court.

The record and agreed facts show the fish ponds had been constructed prior to 1915 and were in active possession and enjoyment by the plaintiffs up to the time of suit, and that plaintiffs never entered into any lease nor paid rent to the defendant for the land. Plaintiffs relied on the earlier Supreme Court registration decision (Exhibit A, Registration Case No. 8719) as part of their proof; that decision, however, had adjudged the defendant entity in public possession and under a claim of o...(Subscriber-Only)

Issues:

  • Did the plaintiffs possess the land and fish ponds in good faith so as to be entitled to indemnity under the Civil Code?
  • If not, is the defendant nevertheless obliged to pay the plaintiffs the value of the fish ponds or to sell them the land at the price claimed?
  • Did the defendant act in bad faith by permitting or tolerating the construction of the fish ponds such that the plaintiffs’...(Subscriber-Only)

Ruling:

  • (Subscriber-Only)

Ratio:

  • (Subscriber-Only)

Doctrine:

  • (Subscriber-Only)

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