Case Summary (G.R. No. L-21027)
Background
The original tax declaration for the subject property was in the name of Victoriana Dulay under Tax Declaration No. 17056. The case alleges that on January 28, 1928, Victoriana Dulay and her son, Restituto D. Merino, sold the property to Juan Galupo. Following Juan Galupo's death, the land was inherited by his son, Mansueto Galupo, Sr. In 1952, Mansueto procured the cancellation of the original tax declaration and obtained a new one under his name. The heirs, plaintiffs in this case, discovered in 1984 that Lina Abalon Lubos was occupying the land.
Initial Proceedings
The trial court rendered a decision on November 26, 1992, favoring the plaintiffs. The court declared them the exclusive and absolute owners of the land, nullified Lubos's title as well as her sale of a portion of the land to Alicio Poldo, and ordered the defendants to vacate and pay damages.
Appeal and Ruling by the Court of Appeals
Lina Abalon Lubos and the spouses Poldo appealed the trial court’s ruling. On August 29, 1997, the Court of Appeals upheld the trial court's decision in its entirety. Following the denial of a motion for reconsideration by the Court of Appeals, the petitioner escalated the matter to the Supreme Court, questioning who among the parties had superior title to the disputed land.
Issue for Resolution
The primary issue for the Supreme Court's determination was whether the petitioner or the respondents held a better right or title to the property in question.
Legal Framework
The Supreme Court emphasized the principle that factual findings of the trial court, which are also affirmed by the Court of Appeals, are generally considered final and not subject to review on appeal. Article 1141 of the Civil Code, pertaining to the prescription of real actions over immovables, states that such actions prescribe after thirty years, thereby delineating the need to ascertain whether the petitioner had obtained the property through acquisitive prescription.
Acquisitive Prescription Analysis
Acquisitive prescription can be ordinary or extraordinary, varying based on whether possession is had in good faith and with just title. The pertinent Civil Code provisions (Articles 1134 and 1137) prescribe periods of possession, indicating that ownership of immovable property may be acquired through ten years of possession in good faith or thirty years of adverse possession without just title and good faith.
Findings on Petitioner’s Claim
The petitioner failed to establish a just title to the property. The trial court found the transaction between Lubos and her father to be fictitious, undermining any claim of good faith. Furthermore, testimonies presented did not conclusively affirm the nature of possession by Juan Abalon, the petitioner's father. Possession needed to be characterized as p
...continue readingCase Syllabus (G.R. No. L-21027)
The Case
- The petitioner, Lina Abalon Lubos, seeks to overturn the decision of the Court of Appeals, which upheld the ruling of the Regional Trial Court in Makati, Branch 66.
- The central ruling determined that the respondents are the absolute owners of a parcel of land, which is the subject of the dispute.
The Facts
- The disputed land measures approximately 10.8224 hectares and is located in Sitio Naganaga, Barrio Cababtuan, Municipality of Pambujan, Northern Samar.
- The land was originally tax declared under the name of Victoriana Dulay as per Tax Declaration No. 17056.
- On January 28, 1928, a private sale (Escritura de Compra y Venta) was executed, wherein Victoriana Dulay and her son sold the property to Juan Galupo.
- Upon Juan Galupo's death, the property passed to his son, Mansueto Galupo, Sr., who successfully canceled the original tax declaration and obtained a new one (Tax Declaration No. 24041) in 1952.
- The tax declaration was further updated in 1985 (Tax Declaration No. 3393) following a general revision.
- The heirs of Mansueto Galupo, Sr. discovered in 1984 that the land was occupied by tenant farmers of Lina Abalon Lubos, who had obtained a new tax declaration (No. 34286) for the land.
- Lubos contended that the land was rightfully inherited from her great-grandmother, Victoriana Dulay, through her father, Juan F. Abalon, who possessed the land for over 30 years before selling it to Lubos in 1975.
- The plaintiffs sought to annul Lubos’s sale