G.R. No. 171068 , September 5, 2007
HEIRS OF MARCELINA ARZADON-CRISOLOGO, et al. vs. AGRIFINA RAÑON, et al.

FACTS

Respondent Agrifina Rañon filed a complaint for quieting of title and injunction against the spouses Montemayor over an unregistered residential lot in Badoc, Ilocos Norte. She claimed her family had possessed the property since 1962, built a house on it, and paid taxes, until a fire destroyed the house in 1986. She later discovered the property was declared in the spouses’ name. Petitioners, the Heirs of Marcelina Arzadon-Crisologo, intervened, asserting ownership through succession from their predecessors-in-interest, the spouses Alcantara, who allegedly bought the lot in 1936. They claimed continuous possession and tax payment. The spouses Montemayor, who had bought from some petitioners, were later dropped from the case after the property was repurchased. The Municipal Circuit Trial Court (MCTC) ruled in favor of the petitioners, declaring them owners of one-half by succession and the other half by acquisitive prescription.

ISSUE

Whether the Court of Appeals erred in reversing the MCTC and ruling that respondents had acquired ownership of the property through extraordinary acquisitive prescription.

RULING

The Supreme Court denied the petition and affirmed the Court of Appeals’ decision. The core legal principle is that ownership of immovable property prescribes through thirty years of uninterrupted adverse possession, without need of title or good faith, under Article 1137 of the Civil Code. The Court found that respondents and their predecessors had possessed the property in the concept of an owner since 1962, a fact substantiated by tax declarations and payments. This possession was public, peaceful, and uninterrupted. The petitioners’ claim of a 1977 interruption—due to a change in the tax declaration—was correctly deemed insufficient. A tax declaration, by itself, is not a conclusive proof of ownership and does not constitute the judicial summons required by law to interrupt prescription. The act of cancelling one tax declaration and issuing another is an administrative, not a judicial, act. Therefore, respondents’ possession from 1962 met the 30-year requirement for extraordinary acquisitive prescription, vesting ownership in them by 1992, prior to the filing of the complaint in 1995. The petitioners’ evidence of earlier possession by their predecessors was insufficient to overcome the established fact of respondents’ long-standing adverse possession.