G.R. No. L-5201
ROMAN CAJUIGAN, administrator of the estate of Jorge Capricho and Clemencia Morales, deceased, plaintiff-appellee, vs. MARIANO NATIVIDAD, ET AL., defendants. MARIANO NATIVIDAD, appellant.
January 13, 1910

FACTS:
Jorge Capricho died intestate in August 1902, indebted to Mariano Natividad. His wife, Clemencia Morales, died intestate in December 1902. In October 1902, prior to her death, Clemencia Morales and Mariano Natividad liquidated the debt, confirming P486.94 was due to Natividad and Clemencia promised to pay or pledge certain carabaos.

After Clemencia’s death, Sotero Morales was appointed administrator of the estate. A committee was appointed in August 1903 to appraise the estate and allow claims. Sometime in December 1902, “within a few weeks after the death of Clemencia Morales,” Sotero Morales delivered three carabaos to Mariano Natividad “en garantia de una deuda” (as security for a debt). Natividad possessed these carabaos continuously from that time until the commencement of this action on July 10, 1907, possessing them in good faith, believing they were turned over in partial payment of his claim. Sotero Morales’ inventory (filed Jan 1907) listed the carabaos and indicated their delivery to Natividad, though his final account stated no debts existed against the estate.

Sotero Morales later died, and Roman Cajuigan was appointed the new administrator. Cajuigan filed an action to recover the carabaos, contending that Sotero Morales, as the first administrator, had no authority to deliver the carabaos to Natividad without express court permission, and that Natividad should have presented his claim to the appointed committee. The lower court sided with Cajuigan, finding Natividad’s possession illegal and ordering the return of the carabaos or payment of their value (P300) plus P495 for their use. Mariano Natividad appealed.

ISSUE:
Can an administrator maintain an action to recover personal property belonging to an estate, which has been in the continuous possession of the defendant for a period of more than four years, where the defendant possessed the property in good faith?

RULING:
No. The Supreme Court reversed the decision of the lower court.

The Court found that Mariano Natividad had held continuous possession of the carabaos from December 1902 until the commencement of the action on July 10, 1907, a period of over four years, and that he possessed them in good faith.

The Court cited Article 1955 of the Civil Code, which provides that “The ownership of personal property prescribes by uninterrupted possession in good faith, for a period of three years.” It also noted Paragraph 3 of Section 43 of the Code of Procedure in Civil Actions, which limits an action for the recovery of personal property to four years.

Without resolving the potential conflict between these two provisions, the Court ruled that under the facts of the case, the plaintiff’s right to recover the carabaos could not be sustained due to the defendant’s continuous possession in good faith for over four years. Therefore, the judgment of the lower court was reversed.