Case Summary (G.R. No. 135602)
Background of the Case
The contention arises from a dispute over the possession and ownership of two parcels of land in Banga, Aklan, originally owned by Marcelino Recasa. Marcelino had three marriages and fathered fifteen children before his death in 1943. His estate was partitioned in 1948, with property designated for each set of heirs corresponding to his marriages. The petitioners acquired the properties from the heirs of Marcelino through a series of sales and set forth their claim to recover possession after being deprived of the land by the private respondent, Simeon Recasa.
Trial Court Ruling
The Regional Trial Court initially ruled in favor of the petitioners, asserting that they had acquired the property through a valid sale and had established their claim to ownership. The trial court emphasized that the petitioners had sufficient title to seek recovery of the land from Simeon Recasa.
Court of Appeals Reversal
On appeal, the Court of Appeals reversed the trial court's decision, ruling the action for recovery was barred by prescription. The appellate court cited that the petitioners waited too long to file their claim, specifically noting that the absence of possession lasted over a decade since the petitioners' predecessor was allegedly dispossessed in 1974, and they filed their claim only in 1987, exceeding the ten-year limit mandated under applicable law.
Prescription and Applicable Law
The Court correctly identified that the claim fell under the rules of extinctive prescription as governed by Article 1141 of the Civil Code, which prescribes a thirty-year period for real actions involving immovables. However, the Court of Appeals' reliance on earlier jurisprudence was deemed inappropriate as it was based on ten-year acquisitive prescription principles which do not apply to this case.
Private Respondent's Claims
Simeon Recasa claimed ownership through ordinary prescription, asserting he possessed the property in good faith for ten years. The Court found this claim unmerited as he lacked just title and good faith because his possession was not based on any recognized legal acquisition of property. The analysis revealed that he entered the land unlawfully, rendering his possession that of a usurper.
Petitioners' Possession Claims
The petitioners, notwithstanding their contract of sale with Rata in 1983, could not automatically claim ownership as formal delivery of the property was essential for the transfer of title. They had not received possession of the property, whic
...continue readingCase Syllabus (G.R. No. 135602)
Case Overview
- This case is a review of the decision made by the Court of Appeals on May 15, 1998, reversing the Regional Trial Court's ruling in favor of the petitioners for the recovery of possession and ownership of two parcels of land in Banga, Aklan.
- The primary legal issues revolve around the prescription of the action for recovery of property and whether private respondent Simeon Recasa acquired ownership through acquisitive prescription.
Background Facts
- The original owner of the disputed lands, Marcelino Recasa, had three marriages and fathered fifteen children.
- Upon Marcelino's death in 1943, his estate was partitioned among his heirs, with each part allocated according to their respective marriages.
- Patronicio Recasa sold the share of heirs from the first marriage to Dominador Recasa, who later sold it to Quirico and Purificacion Seraspi.
- The Seraspis used the lands as collateral for a loan from Kalibo Rural Bank, Inc. (KRBI), leading to a foreclosure and subsequent sale to Manuel Rata.
- Rata allowed Quirico Seraspi to administer the property until Simeon Recasa forcefully entered the lands during Quirico's illness in 1974.
Legal Proceedings
- The Seraspis filed a complaint against Simeon Recasa in 1983 for recovery of possession after purchasing the lands from Manuel Rata.
- The trial court ruled in favor of the