GR L 9212; (January, 1915) (Digest)
G.R. No. L-9212; January 28, 1915
JACINTO DE JESUS Y LADAO, plaintiff-appellee, vs. LUIS MANZANO, defendant-appellant.
FACTS:
Plaintiff Jacinto de Jesus y Ladao filed an action in the Court of First Instance of Zambales to recover ownership and possession of a parcel of rice land located in Bacao, San Marcelino, Zambales. He based his ownership on a possessory information title judicially approved on July 16, 1895, and recorded in the property registry on February 20, 1896. He alleged he had possessed the land publicly and peaceably until January 1912, when he was deprived of possession pursuant to a judgment in a prior forcible entry and detainer case (Case No. 157) filed against him by the defendant, Luis Manzano. The defendant, in his answer, claimed ownership of the same land, asserting it was part of his property in the sitio of Tabuyeyeng and that he had possessed it for over fifteen years (later testified as over fifty years). He also invoked the judgment in the prior detainer case as res judicata. The trial court ruled in favor of the plaintiff, ordering the defendant to deliver the land and pay costs. The defendant appealed.
ISSUE:
Whether the plaintiff has a superior right of ownership over the disputed land, thereby entitling him to recover its possession, notwithstanding the prior judgment in the forcible entry and detainer case.
RULING:
The Supreme Court affirmed the trial court’s judgment, ruling in favor of the plaintiff.
1. Plaintiff’s Title and Possession: The plaintiff’s ownership was sufficiently established by his possessory information title (Exhibit B), which was duly approved and recorded. In those proceedings, the defendant, as an adjoining landowner, was notified and raised no objection, implying recognition of the plaintiff’s possession. The evidence, including a sketch (Exhibit A) admitted by both parties, clearly identified the disputed land as the one described in the plaintiff’s title and situated in Bacao.
3. Conversion of Possessory Title: The Court noted that while Article 393 of the Mortgage Law required twenty years for a possessory information to convert into a record of ownership, sections 39, 40, and 41 of the Code of Civil Procedure established a ten-year period. Sixteen years had elapsed since the registration of the plaintiff’s title, sufficient to consolidate his ownership.
4. Res Judicata Not Applicable: The judgment in the prior forcible entry and detainer case (Case No. 157) did not constitute res judicata in this action for recovery of ownership. Under Section 87 of the Code of Civil Procedure, a judgment in a detainer action is not conclusive in a subsequent action between the same parties involving title to the property. Therefore, the plaintiff’s action to recover possession based on ownership was not barred.
The Supreme Court held that the plaintiff proved a better right of ownership and was entitled to recover possession of the land. The appealed judgment was affirmed.
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