G.R. No. 141007 . September 13, 2005
ADORACION REYES BAUTISTA, ET AL., Petitioners, vs. CELIA REYES POBLETE, ET AL., Respondents.

FACTS

Private respondents, successors-in-interest of Socorro Reyes, filed a petition for registration of a 6.2556-hectare parcel of land (Lot 1243). They claimed the lot was donated to Socorro by her father, Marcelo Reyes, Sr., in 1932, and that they and their predecessors had been in open, continuous, and notorious possession in the concept of owners for over 50 years. The original deed of donation was allegedly destroyed in a fire. Petitioners, Marcelo Sr.’s children by a third marriage, opposed the application, asserting the lot formed part of their father’s estate and should be awarded to them as his lawful heirs. The trial court dismissed the registration petition due to the absence of the written deed of donation.
On appeal, the Court of Appeals reversed the trial court. It found that Socorro had taken possession of the land in 1934, had it cadastrally surveyed in her name in 1940, declared it for taxation in her name in 1948, and paid taxes thereon. She later sold the land to the private respondents in 1983. The appellate court held that even assuming the donation was invalid, Socorro’s long-term adverse possession could ripen into ownership through acquisitive prescription.

ISSUE

Whether private respondents have acquired a registrable title to Lot 1243 through acquisitive prescription.

RULING

Yes. The Supreme Court affirmed the Court of Appeals’ decision, ruling that private respondents acquired ownership through extraordinary acquisitive prescription. The Court emphasized that the nature of Socorro’s possession was adverse, continuous, open, public, peaceful, and in the concept of an owner from 1934 onward. Her acts of dominion—including exclusive enjoyment of the land’s fruits, having it cadastrally surveyed in her name, and consistently paying real property taxes—were clear and unequivocal. These acts constituted an effective repudiation of any implied trust that might have initially existed in favor of the other heirs.
Applying the Code of Civil Procedure, which was in force at the commencement of her possession, the Court held that ten years of adverse possession vested full and complete title in the actual possessor. Socorro’s possession far exceeded this period. The petitioners’ failure to object to her exclusive possession and acts of ownership for decades, until the land was sold for a substantial sum, barred their claim. The findings of fact of the Court of Appeals, being supported by the evidence on record, are conclusive. Therefore, no co-ownership existed, and the respondents acquired a registrable title through prescription.