G.R. No. 26095, March 2, 1927
RAFAEL SANTOS, plaintiff-appellant, vs. PEDRO DE LA VIÑA, defendant-appellee.

ROSARIO AMANCIO, ET AL., intervenors.

FACTS

Rafael Santos filed an action to recover ownership and possession of three parcels of land (consolidated as the Hacienda “Manuel” or “Dulungan”) in Capiz, and to claim damages from Pedro de la Viña. Santos traced his title back to acquisitions made in the 1890s by Alvaro Alcantara de Santos and his son from various original owners. This property passed through several conveyances, ultimately being sold to Santos in 1924. De la Viña claimed ownership through various deeds executed in the early 1920s, deriving title from different persons. An official survey plan (Exhibit 18) from October 1914 showed that specific lots within the hacienda were then claimed by persons from whom De la Viña later derived his title. The trial court absolved De la Viña, prompting Santos’s appeal.

ISSUE

Whether the defendant, Pedro de la Viña, had acquired ownership over the disputed parcels of land through acquisitive prescription.

RULING

YES, in part. The Supreme Court affirmed the trial court’s judgment with respect to the lots where De la Viña proved adverse possession for the required prescriptive period, but reversed it for the lots where he failed to do so.
1. For Lots 1-a, 1-c, 1-d, 1-h, 1-i, 2-a, and 2-b: The Court found that De la Viña and his predecessors-in-interest had been in adverse possession for more than ten years prior to the filing of the suit. The 1914 survey plan and supporting oral testimony established that these specific parcels were already claimed and occupied by others at that time, and De la Viña’s title was derived from these claimants. Therefore, Santos’s action for recovery as to these lots was barred by prescription.
2. For Lot 2-c and the parts of Lots 1 and 2 derived from Claudio Buendia: The Court found that De la Viña failed to prove adverse possession for the prescriptive period. The 1914 survey did not show Claudio Buendia as a claimant, giving rise to the presumption that he had no interest at that time. The oral testimony also did not establish prior occupation. Consequently, Santos’s title to these portions, being uncontested by a prescriptive claim, was upheld.

DISPOSITIVE:
The judgment of the trial court was AFFIRMED with respect to lots 1-a, 1-c, 1-d, 1-h, 1-i, 2-a, and 2-b. It was REVERSED with respect to lot 2-c, the part of lot 2 north of 2-c, and all parts of lot 1 held by De la Viña under title derived from Claudio Buendia (excluding the lots affirmed). Judgment was entered for plaintiff Rafael Santos to recover these specific portions. No costs were awarded.