Case Summary (G.R. No. L-2176)
Factual Background
Sotera Arboso originally owned the parcel of land, and following her death in 1920, her children continued to benefit from it through Roman Budak, who managed the land. In 1920, Budak falsely claimed ownership, stating he inherited the land from Sotera, and subsequently had the land registered in his name for tax purposes. His sale of the land to Doroteo Andrade in 1926 followed despite warnings of his lack of true ownership. Andrade then declared the property and paid taxes until 1946. Following the sale, Arboso’s heirs attempted to reclaim the land through various legal means, but all actions ultimately failed.
Legal Actions and Controversies
Subsequent to the sale, the Arboso heirs attempted to assert their ownership by gathering coconuts from the land, actions which led to Andrade filing for ejectment against them in 1947. The ejectment was ruled in favor of Andrade, effectively ordering the Arboso heirs to desist from interfering with Andrade’s possession. Despite these rulings, the Arboso heirs continued to enter the land, inciting further disputes culminating in Consolacion Arboso's present legal action against Andrade.
Legal Issue
The primary legal issue is whether Doroteo Andrade acquired ownership of the land by prescription, given the historical context of the property’s possession.
Applicable Law on Prescription
The legal framework governing prescription, particularly the Civil Code articles addressing possession, was invoked in the analysis. Interruption of possession can occur through natural or civil means, with civil interruption caused by legal actions against the possessor. However, if a suit does not yield a favorable judgment for the plaintiff, it does not toll the period for acquiring ownership by prescription. The court referenced numerous authorities confirming that an unsuccessful suit does not interrupt the continuity of adverse possession.
Conclusion on Ownership by Prescription
Evaluating the case facts against the framework of ownership by prescription, the court concluded that Andrade indeed acquired ownership of the land by adverse possession. The Arboso heirs’ various attempts to recover the propert
...continue readingCase Syllabus (G.R. No. L-2176)
Case Background
- The case involves an appeal from the Court of First Instance of Leyte regarding the ownership of a parcel of land.
- The plaintiff, Consolacion Arboso, appeals a decision declaring the defendant, Doroteo Andrade, as the owner of the land in question.
- The appeal focuses solely on legal questions, with the facts established in the original decision being accepted as accurate.
Historical Ownership
- Sotera Arboso was the original owner of the land since 1917, with the property declared in her name for tax purposes (Exhibit A).
- After her death in 1920, her children, including Consolacion Arboso, continued to receive the produce from the land, managed by Roman Budak.
- In 1920, Roman Budak claimed ownership of the land through an affidavit, asserting he inherited it from Sotera Arboso, leading to its declaration in his name for tax purposes (Exhibit C).
Transactions and Legal Actions
- In December 1926, Budak sold the land to Doroteo Andrade, who was warned that Budak was not the rightful owner.
- Andrade declared the land under his name and paid taxes on it until 1946.
- In 1927, Sotera Arboso’s children attempted to reclaim the land, resulting in a theft accusation against them by Andrade, which was later dismissed as a civil matter.
- The A