Title
Domalsin vs. Spouses Valenciano
Case
G.R. No. 158687
Decision Date
Jan 25, 2006
Dispute over land near Kennon Road; petitioner claimed possession since 1979, respondents built without consent. SC ruled land public dominion, ordered respondents to vacate, upheld petitioner's prior possession.
A

Case Summary (G.R. No. 243578)

Procedural Background

The petition seeks to overturn the decision of the Court of Appeals which reversed the ruling of the Regional Trial Court (RTC) of La Trinidad, Benguet, affirming the Municipal Circuit Trial Court's (MCTC) declaration that Domalsin was the actual possessor of the contested lot and ordering the Valencianos to vacate the premises.

Factual Allegations

Domalsin alleges that he has possessed the property since 1979, declaring it for taxation in 1983 and introducing various improvements. He contends that the Valencianos entered the property without authority on August 1, 1998, for constructing a cement building. The Valencianos counter that their construction was with proper consent from the DPWH and was actually initiated by prior residents, not Domalsin.

Initial Court Rulings

The MCTC ruled in favor of Domalsin, stating he had prior material possession and that the destruction of his house during the 1990 earthquake did not signify abandonment of the property. The RTC affirmed this decision, emphasizing the continued payment of taxes by Domalsin as evidence of his intent not to abandon the property.

Court of Appeals Decision

Upon appeal by the Valencianos, the Court of Appeals ruled that the subject property is a public road-right-of-way, thereby voiding any claim of ownership by the parties. It stressed that possession cannot ripen into ownership regarding public dominion properties, thus concluding that neither party had a rightful claim.

Issues on Appeal

Domalsin contested the Appeals Court's assertion that he abandoned the property and argued that the reversal of the lower court's rulings was incorrect. He maintained that the possession of the property should be awarded based on his prior physical occupancy, rather than the respondents' current possession.

Determination of Possession and Claim

The Supreme Court highlighted that the contested land is not subject to private ownership due to its designation as public dominion. Therefore, the Court elaborated that neither party could assert a legitimate claim to possess the land. The Court emphasized that merely being in possession does not confer ownership rights over public property.

Final Ruling

Finding that neither party could claim ownership under these legal principles, the Supreme Court determined to set aside all preceding decisions relating to ownership or pos

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