Title
Tan vs. Ramirez
Case
G.R. No. 158929
Decision Date
Aug 3, 2010
In the case of Tan v. Ramirez, the Supreme Court ruled in favor of Tan, declaring her as the rightful owner of one-fourth of a disputed parcel of land, overturning the Court of Appeals' decision that favored the respondents based on a compromise agreement and a contract of sale.
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Case Digest (G.R. No. 158929)

Facts:

  • The case Tan v. Ramirez, G.R. No. 158929, was decided by the Supreme Court on August 3, 2010.
  • The dispute centers on the ownership of Cadastral Lot No. 3483 in Mahaba, Apid, Inopacan, Leyte.
  • Petitioner Rosario P. Tan initiated a case on August 11, 1998, in the Municipal Circuit Trial Court (MCTC) to recover half of the property from respondents: Artemio G. Ramirez, Moises G. Ramirez, Rodrigo G. Ramirez, Domingo G. Ramirez, and Modesta Ramirez Andrade.
  • Rosario asserted that her great-grandfather, Catalino Jaca Valenzona, was the original owner, supported by a 1915 Tax Declaration.
  • The respondents based their claim on Gavino Oyao, who had cultivated the land since 1956 and acquired it through various transactions.
  • The MCTC initially ruled in favor of Rosario, granting her one-fourth of the property.
  • The Regional Trial Court (RTC) modified this decision, leading the respondents to appeal to the Court of Appeals (CA).
  • The CA reversed the lower courts' decisions, declaring the respondents as the rightful owners, prompting Rosario to seek a review from the Supreme Court.

Issue:

  • (Unlock)

Ruling:

  • The Supreme Court ruled in favor of Rosario P. Tan, reversing the Court of Appeals' decision.
  • The Court reinstated the MCTC's ruling, affirming Rosario's ownership of one-fourth of the disputed property.
  • The Court concluded that the respondents did not possess the pr...(Unlock)

Ratio:

  • The Supreme Court clarified that prescription for acquiring ownership necessitates possession that is public, peaceful, uninterrupted, and adverse.
  • For ordinary acquisitive prescription, possession must be in good faith and with just title for a duration of ten years.
  • The Court found that the CA incorrectly relied on the compromise agreement and contract of sale to substantiate the respondents' claims of good faith and just title.
  • The compromise agreement was merely a means of dispute resolution and did not confer ownership rights.
  • The Court noted that Roberto Ramirez acquired the property while...continue reading

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