G.R. No. 133289 - Antiporda, Jr. vs. Garchitorena

The case stemmed from a complaint filed on May 30, 1967, where petitioners Antonio Solis and Angela Solis Calimlim claimed co-ownership of a residential land parcel in Calasiao, Pangasinan.
The disputed property, an unregistered parcel of 536 square meters (being the eastern portion of a larger 1,073-square-meter lot), was originally inherited from their parents, Simeon Solis and Petronila Bauzon.
Defendants Jose Solis and Florencia Dioquino, private respondents, based their claim on possessing the eastern portion by means of a donation propter nuptias purportedly executed in 1931 by Tomas Solis and Hermenegilda Jimenez.
A Motion for the Issuance of a Writ of Preliminary Mandatory Injunction was filed by the petitioners on November 21, 1968, to prevent further construction by the defendants. This motion was granted on December 11, 1968.
A partial stipulation of facts was filed on February 17, 1969, where both parties agreed on key descriptions of the property, its history of ownership, and its taxation declarations from before 1918 up to 1967.

The trial court conducted a single setting on June 25, 1969, where both evidence and oral testimony were presented.
It was found that the defendants had possessed the eastern portion of the property for over 30 years.
Despite the long possession, the trial court ruled in favor of petitioners, holding that the possession could not be held adversely against petitioners because they had shown a better title.
The trial court emphasized that although the defendants exhibited the deed of donation propter nuptias from Tomas Solis, there was no evidence proving that title had legitimately passed from Simeon Solis (previous owner) to Tomas Solis.
The trial court declared Antonio Solis as the exclusive owner and ordered the defendants to vacate the property, pay attorney’s fees of P800, and shoulder the cost of the suit.

Defendants, dissatisfied with the trial court’s decision, appealed to the Court of Appeals.
In its decision dated May 12, 1977, the Court of Appeals reversed the trial court’s ruling.
The appellate court declared that the defendants had been in actual, continuous, open, public, and adverse possession of the eastern portion of the property since 1933.
Evidence such as the payment of realty taxes (indicating possession in the capacity of an owner), construction of a house, and exclusive control of the eastern lot supported the appellate finding.
The appellate court held that the donation propter nuptias, despite controversies on its validity, had led the defendants to take possession, thereby giving rise to their just title via prescription.
The Court of Appeals also determined that the cause of action for petitioners accrued in 1933 (or even in 1941 as argued later), ultimately prescribing the claim.
The appellate decision was rendered final when the Motion for Reconsideration was denied on August 3, 1977.

Petitioners Antonio Solis and Angela Solis Calimlim sought a review of the Court of Appeals decision, admitting the findings of fact but objecting to the conclusions drawn regarding adverse possession and prescription.
They contended that:

The defendants’ possession was not adverse but merely tolerated.
The donation propter nuptias did not transfer title as the alleged donor had no valid title to convey.
The appellate court erred in determining the time when their cause of action accrued.

The petition for review on certiorari was ultimately filed on September 19, 1977.
Subsequent submissions included the petitioners’ brief, while the respondents failed to file their brief within the prescribed period.
The Supreme Court considered the petition without the respondents’ brief and eventually denied the petition, thereby affirming the decision of the Court of Appeals.

Whether the possession of the disputed 536-square-meter parcel by the defendants was adverse, continuous, and in the concept of an owner as required by prescription.
Whether such possession, initiated in 1933, was properly established through various acts of dominion such as constructing a residence and paying realty taxes.

Whether the donation propter nuptias executed in 1931 by Tomas Solis could confer title, notwithstanding the allegation that Tomas Solis had no valid title to the property.
The legal implications of a potentially void donation serving as a basis for acquiring ownership by prescription.

Whether the petitioners’ claim was barred by prescription under the then-applicable statutes, considering that the defendants had been in possession for over 20 to 30 years.
The determination of the exact moment when the cause of action accrued, whether it was in 1933 due to the start of adverse possession or later when the petitioners’ title was effectively repudiated.

The weight and finality of the Court of Appeals’ findings regarding the possession and acts of ownership by the defendants.
Whether the petitioners’ evidence of a better title was sufficient to offset the adverse possession established by the defendants.