B.M. No. 1154 - IN RE: Haron S. Meling

Plaintiff, Crispulo Sideco, owned a hacienda and a caraballa, which was part of his livestock, branded with the letters "S. P."
The brand "S. P." had been used and registered by the plaintiff for over thirty years, with registration recorded on May 4, 1904, in the municipality of San Isidro.

In the year 1900, a caraballa aged above five years, belonging to the plaintiff, disappeared from his hacienda.
In July 1907, a caraballa bearing the brand "S. P." and additionally marked with the number 23 was found in the possession of Francisco Pascua, along with two of its calves aged about 2 or 3 years.

Defendant Francisco Pascua purchased the animal on March 9, 1903, for a sum of P110 from Guillermo Zamora.
Guillermo Zamora had, in turn, purchased the caraballa for P110 from Salvador Pangangban, who was the duly registered owner as of March 30, 1901.
Each transfer of ownership was supported by the necessary certificates of property and transfer, executed in accordance with the relevant legal provisions.

Plaintiff initiated legal proceedings in August 1907, seeking the recovery of the caraballa and its two calves, asserting that the animal in defendant’s possession was the same one that disappeared in 1900.
Plaintiff’s evidence regarding the identity of the lost animal and the one in defendant’s possession was found to be not wholly satisfactory.

Defendant’s title was argued to have been acquired by prescription under Article 1955 of the Civil Code, which requires uninterrupted possession in good faith for three years (in personal property cases, six years may also be applicable).
The defendant presented unimpeached documentary and oral evidence proving uninterrupted possession and a bona fide purchase.
The period of uninterrupted possession started from his purchase on March 9, 1903, well over the required prescriptive period before the action was instituted.

Plaintiff contended that the prescriptive period did not begin until he discovered the location of the caraballa in July 1907.
Plaintiff relied on Article 1956 to argue that a thief or an accomplice cannot acquire ownership by prescription; however, there was no evidence linking defendant or his predecessors to any theft.

Under Article 434 of the Civil Code, good faith is presumed, placing the burden on the accuser to prove bad faith.
Defendant’s evidence affirmed his good faith purchase and continuous possession, leaving no substantial ground for alleging bad faith or theft in relation to his acquisition.

Whether the defendant acquired title to the caraballa and calves by prescription under Article 1955 of the Civil Code through uninterrupted, good faith possession.
Whether the evidentiary record sufficiently established the defendant’s bona fide purchase and continuous possession to justify the application of prescription notwithstanding the alleged disappearance of the animal in 1900.
Whether the argument based on Article 1956, which excludes prescription as a means to acquire stolen property, was applicable given the lack of evidence linking the defendant or his predecessors to the alleged theft.
Whether the running of the prescriptive period should commence from the defendant’s date of purchase (March 9, 1903) or from the moment the plaintiff purportedly discovered the animal's disappearance (July 1907).