Title
Solis vs. Court of Appeals
Case
G.R. No. L-46753-54
Decision Date
Aug 25, 1989
Petitioners claimed co-ownership of inherited land; respondents asserted adverse possession since 1933 via a void donation. SC upheld respondents' ownership due to continuous, open, adverse possession and tax payments, barring petitioners' claim under prescription.

Case Summary (G.R. No. L-46753-54)

Background of the Case

The petitioners claim co-ownership of a total of 1,073 square meters of residential land, inherited from their parents. In 1939, they allowed the respondents to construct a house on the eastern part of their property under the condition that they would vacate when able. In 1965, the petitioners demanded that the respondents vacate the premises, which the respondents refused.

Defendants’ Claim and Legal Actions

The respondents asserted ownership through a "donacion propter nuptias" from spouses Tomas Solis and Hermenegilda Jimenez, claiming that since 1931 they had openly and continuously possessed the property. Subsequent legal actions saw the petitioners seek a preliminary injunction against the respondents in 1968, which was granted by the trial court.

Trial Court Proceedings

During the trial held on June 25, 1969, the court considered evidence from both parties. The trial court recognized that the respondents had been in possession for over thirty years but ruled that such possession could not be considered adverse to the petitioners due to the latter's better title stemming from their family’s ownership history.

Ruling of the Trial Court

The trial court affirmed that Antonio Solis was the exclusive owner of the disputed land, ordering the respondents to vacate and pay attorney's fees to the petitioners. The trial court concluded that the respondents had failed to present evidence proving their title through Tomas Solis.

Court of Appeals Decision

Dissatisfied with the trial court's verdict, the respondents appealed to the Court of Appeals, which reversed the trial court's decision on May 12, 1977. The appellate court determined that the respondents had lawfully possessed the eastern half of the land since 1933, backed by the absence of a proper conveyance from Simeon Solis to Tomas Solis.

Petition for Review

The petitioners filed a petition for review on certiorari, admitting the factual findings of the Court of Appeals but contesting the conclusions drawn from these findings. They argued that possession was merely tolerated and not adverse, and also challenged the appellate court's acceptance of the donation as valid despite the lack of title in the donor.

Legal Arguments and Rationale

The Supreme Court reaffirmed the appellate court's factual findings, stating that possession of the respondents was adverse and uninterrupted, entitling them to ownership under principles of acquisitive prescription. The court noted that the respondents exercised acts of ownership, such as paying taxes and constructing a house, supporting th

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