Case Summary (G.R. No. L-8018)
Procedural Background
The complaint was filed on August 7, 1950, following a history of possession that commenced when the plaintiffs inherited the land from their widowed aunt, Estefania Atun, who had died without issue. The plaintiffs claimed that they had initially possessed the land from 1927 to 1930, after which they allowed Silvestra Nunez, the sister of defendant Eusebio Nunez, to cultivate the land in exchange for part of the harvest. However, in 1940, Eusebio Nunez assumed control of the property and subsequently sold it to Diego Belga.
Dismissal Grounds
The lower court dismissed the complaint on the grounds of the prescription of action, asserting that the plaintiffs’ right to file for recovery had expired as the action was filed after a ten-year period following their loss of possession in 1940. Additionally, the court stated that the plaintiffs failed to demonstrate a superior title over the defendants, who were presumed to possess the land lawfully.
Legal Principles and Prescription
In addressing the appeals, it was determined that the trial court erred in its dismissal. Notably, the land in question was covered by a Torrens title registered in Estefania Atun's name. According to Section 40 of Act 496, no title to registered land can be acquired through prescription or adverse possession against the rights of the registered owner. Jurisprudence confirms that the registered owner's right to recover possession is imprescriptible, meaning it cannot be lost through the mere passage of time.
Ownership and Heirs' Rights
The ruling further clarified that characteristically, from the perspective of law, the rights of hereditary successors to reclaim registered property are no different from those of the deceased owner, as the ownership rights do not change upon succession. The plaintiffs qualified as legal heirs of Estefania Atun and could file for recovery of
...continue readingCase Syllabus (G.R. No. L-8018)
Case Background
- The case concerns an appeal from an order of the Court of First Instance of Albay which dismissed the plaintiffs' complaint for the recovery of a parcel of registered land.
- The land is registered under Original Certificate of Title No. 11696 in the name of Estefania Atun, the deceased aunt of the plaintiffs.
- The plaintiffs filed their complaint on August 7, 1950.
Facts of the Case
- The plaintiffs, Gil Atun, Camila Atun, and Dorotea Atun, are the heirs of Estefania Atun, who died without issue.
- The plaintiffs possessed the land from 1927 to 1930, after which Gil Atun transferred possession to Silvestra Nunez for cultivation.
- Silvestra Nunez paid the plaintiffs a portion of the harvest as rental.
- In 1940, Silvestra Nunez transferred the land to Eusebio Nunez, who subsequently refused to recognize the plaintiffs' ownership and failed to deliver their share of the produce.
- Eusebio Nunez later sold the land to Diego Belga, who acquired the property with knowledge that it belonged to the plaintiffs.
Court Proceedings
- Defendants filed a demurrer to the evidence after the plaintiffs rested their case, leading to the dismissal of the complaint based on the expiration of the ten-year period for recovery under section 40 of Act 190.
- The trial court ruled th