Title
Valmonte vs. Villaroman
Case
G.R. No. 28394
Decision Date
Oct 22, 1928
Pedro Villaroman’s adverse possession of land is upheld despite the discovery of potential coheirs, affirming his ownership unaffected by the decree of registration and lis pendens.
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Case Digest (G.R. No. 28394)

Facts:

  • Engracio L. Valmonte et al. are the plaintiffs; Pedro Villaroman is the defendant and appellant.
  • Buenaventura Valmonte died in 1909, leaving a widow, Celestina Marin, and children from two marriages.
  • His first marriage produced three sons: Marcelino, Doroteo, and Manuel Valmonte; the second marriage resulted in four children: Dominga, Ignacia, Hipolito, and Maria Valmonte.
  • The heirs sold a parcel of land to Villaroman on July 15, 1914, for P2,100, with a remaining balance of P600 due later.
  • Villaroman defaulted on the payment, leading the heirs to file a lawsuit on February 14, 1926, to recover the unpaid balance.
  • Villaroman argued he believed the vendors inherited the land from their father, Doroteo Valmonte, and needed waivers from other heirs.
  • The plaintiffs sought a partition of the land, claiming co-ownership rights.
  • The trial court ruled in favor of the plaintiffs, ordering partition and requiring Villaroman to account for income from the land.
  • Villaroman appealed, asserting he had possessed the land as an owner since 1914 and that his certificate of title was conclusive.

Issue:

  • (Unlock)

Ruling:

  • The Supreme Court ruled that the trial court erred in finding that Villaroman had not possessed the land continuously, peacefully, publicly, and adversely since July 15, 1914.
  • The Court also ruled that the trial court erred in holding that Villaroman's...(Unlock)

Ratio:

  • The Supreme Court's decision was based on the principle of acquisitive prescription, allowing ownership through continuous and uninterrupted possession for a specified period.
  • Villaroman had possessed the land openly and adversely since 1914, declaring it for tax purposes and cultivating it without interruption.
  • The plaintiffs had previously acquiesced to the sale, weakening their later...continue reading

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