Case Summary (G.R. No. 184109)
Antecedent Facts
Doroteo Espinocilla owned Lot No. 552, a 570 square meter parcel of land, which was divided among his five children after his death. Dionisia, one of the children, died without issue, and Macario, another child, asserted ownership of her share based on an alleged donation purportedly executed in 1945. Macario later sold portions of the land to his son Roger, who further transferred part of the property to Caridad Atienza, leading to the current dispute over the remaining portions.
Case for Petitioner
Petitioner Mercado claims ownership of 171 square meters of Lot No. 552, comprising inheritance from his mother, Salvacion (142.5 sq. m.), and a purchase from his aunt, Aspren (28.5 sq. m.). He alleges that he is being encroached upon by 39 square meters of land currently occupied by respondents. Mercado argues that the partition made among Doroteo’s heirs did not include Dionisia’s share, asserting that Macario’s ownership claims are invalid and that the illegal occupation warrants his reclaiming of the encroached area.
Case for Respondents
Respondents Belen and Ferdinand Espinocilla acknowledge the initial inheritance of Lot No. 552 but maintain their ownership through acquisitive prescription, having occupied the land since the oral partition among the remaining heirs after Dionisia’s death. They contend that they have maintained public, peaceful, and uninterrupted possession of their respective land portions, effectively negating Mercado’s claims of encroachment.
Trial Court Decision
The Regional Trial Court (RTC) ruled in favor of the petitioner, recognizing his right to 171 square meters of the property. The RTC deemed Macario’s 1948 affidavit invalid due to lack of public documentation proving Dionisia's donation. This ruling included a declaration of partial nullity of transactions affecting the property and mandated an actual partition among the heirs to determine boundaries. The decision temporarily withheld the transfer of possession of the disputed 39 square meters until partitioning could clarify ownership.
Court of Appeals Decision
On appeal, the Court of Appeals reversed the RTC’s rulings, concluding that the respondents acquired ownership through extraordinary acquisitive prescription due to uninterrupted possession for over 30 years. The appellate court recognized that the oral partition executed among Doroteo's heirs effectively concluded their co-ownership in 1945, thereby dismissing Mercado's complaint based on the rule of prescription.
Core Legal Issues
The central question addressed by the appellate court was whether Mercado's claim was barred by the prescription, which can effectively extinguish rights to property through the passage of time under specific conditions. The Court discussed ordinary and extraordinary acquisitive prescription, emphasizing that extraordinary prescription allows for ownership rights to be acquired without title under continuous, adverse possession for 30 years.
Ruling of the Supreme Court
The Supreme Court upheld the Court of Appeals ruling, affi
...continue readingCase Syllabus (G.R. No. 184109)
Background and Parties Involved
- Petitioner: Celerino E. Mercado, seeking recovery of possession, quieting of title, partial declaration of nullity of deeds/documents, and damages.
- Respondents: Belen Espinocilla and Ferdinand Espinocilla.
- Subject property: Lot No. 552, 570 sq. m., located at Magsaysay Avenue, Zone 5, Bulan, Sorsogon.
- Original owner: Doroteo Espinocilla, who divided property equally among his five children (Salvacion, Aspren, Isabel, Macario, Dionisia).
- Dionisia died without issue; Macario took possession of her share, claiming donation through a 1948 affidavit.
Facts and Ownership History
- The lot was divided equally: each child inherited 114 sq. m.
- Dionisia's 114 sq. m. share became subject to dispute, as Macario claimed ownership via donation and possession.
- Macario sold 225 sq. m. in 1977 to his son Roger Espinocilla (husband of respondent Belen Espinocilla).
- In 1985, Roger sold 114 sq. m. to Caridad Atienza.
- Actual surveys showed divided occupation among respondents and petitioner: Belen (109 sq. m.), Caridad Atienza (120 sq. m.), Caroline Yu (209 sq. m.), and petitioner Mercado (132 sq. m.).
Petitioner's Claims
- Petitioner claims ownership and possession of 171 sq. m. (142.5 sq. m. inherited from mother Salvacion and 28.5 sq. m. bought from aunt Aspren).
- He alleges respondents encroach on his rightful share by 39 sq. m.
- Petitioner also challenges the validity of Macario's acquisition of Dionisia's share, alleging fraud.
Respondents' Position
- Acknowledge that each child inherited 114 sq. m.
- Claim Macario's increased share, including Dionisia's, was legitimately possessed and subsequently sold.
- Assert possession in the concept of owner through acquisitive prescription.
- Deny basis for petitioner's claim of encroachment.
Regional Trial Court Decision
- Held in favor of petitioner, granting him 171 sq. m.
- Determined Macario's 1948 affida