GR 139136; (January, 2002) (Digest)
G.R. No. 139136; January 16, 2002
LINA ABALON LUBOS, petitioner, vs. MARITES GALUPO, DELIA GALUPO, JUAN GALUPO, PRUDENCIO GALUPO, PRECIOSA GALUPO and MANSUETO GALUPO, JR., respondents.
FACTS
The case involves a dispute over a 10.8-hectare land in Northern Samar, originally owned by Victoriana Dulay. Respondents, heirs of Mansueto Galupo, Sr., claim ownership through a 1928 Spanish “Escritura de Compra y Venta” wherein Dulay and her son sold the property to Juan Galupo. They allege that after discovering petitioner Lina Abalon Lubos’s tenants occupying the land in 1984, they found Lubos had secured a new tax declaration in her name and had sold a portion to the Poldo spouses.
Petitioner Lubos asserts ownership, claiming the land was sold by Dulay to her father, Juan Abalon, from whom she acquired it via a 1975 deed of sale. She argues the respondents’ Spanish document is inadmissible and that her long possession establishes acquisitive prescription. The trial court ruled for the respondents, declaring them the absolute owners and nullifying Lubos’s sale, a decision affirmed by the Court of Appeals.
ISSUE
Who between the parties has a better right or title to the subject property?
RULING
The Supreme Court denied the petition, affirming the lower courts’ rulings. The core legal logic rests on prescription and the failure to establish a valid title chain. For acquisitive prescription, either ordinary (10 years with good faith and just title) or extraordinary (30 years without need of title or good faith), the possessor must prove the requisite elements. The trial court found the deed between Lubos and her father to be fictitious, negating just title. Her good faith was also negated by the absence of any documentary proof of the alleged sale from the original owner, Victoriana Dulay, to her father, Juan Abalon.
In contrast, respondents established a superior claim. Their 1928 “Escritura” was admissible as an ancient document, not objected to at trial. This document formed a clear chain of title from Dulay to Juan Galupo, then by inheritance to Mansueto Galupo, Sr., and finally to the respondents. Since Lubos failed to prove any mode of acquisition from the true owner, her possession, however long, could not ripen into ownership. The factual findings of the lower courts on these matters are conclusive. Therefore, respondents retained their imprescriptible right to recover the property as true owners.