G.R. No. 171571; March 24, 2008
REPUBLIC OF THE PHILIPPINES, Represented by MACTAN-CEBU INTERNATIONAL AIRPORT AUTHORITY (MCIAA), Petitioner, vs. HEIRS OF FRANCISCA DIGNOS-SORONO, et al., Respondents.

FACTS

Lot Nos. 2296 and 2316 were adjudicated in 1929 by the Court of First Instance of Cebu to several co-owners, including Francisca Dignos, Tito Dignos, and others, each holding distinct fractional shares. The lots were never partitioned. In 1957, the heirs of Tito Dignos, who owned only a 1/4 share, executed an “Extrajudicial Settlement and Sale” conveying the entirety of both lots to the Civil Aeronautics Administration (CAA), predecessor of petitioner MCIAA, without the knowledge or consent of the other co-owners (respondents’ predecessors). In 1996, MCIAA erected a security fence on Lot No. 2316, issued tax declarations in its name for both lots, and allowed third parties to occupy portions, prompting respondents to file an action for quieting of title and legal redemption.
Petitioner MCIAA claimed ownership through open, continuous, exclusive, and notorious possession since the 1957 sale, arguing it acquired title by acquisitive prescription, either as a purchaser in good faith or through extraordinary prescription over 30 years. It also contended the action was barred by laches and estoppel.

ISSUE

Whether respondents, as co-owners, retain their rights over the lots and are entitled to legal redemption despite the 1957 sale and MCIAA’s long-term possession.

RULING

The Supreme Court denied the petition, affirming the lower courts’ decisions in favor of respondents. The legal logic rests on the nature of co-ownership and the inapplicability of prescription to registered land. First, the 1957 sale by the heirs of Tito Dignos covered only their 1/4 share; it could not validly transfer the remaining 3/4 interest belonging to the other co-owners. Consequently, MCIAA acquired only that 1/4 share. Second, the lots, having been adjudicated by a cadastral court decree, are considered registered land under Act No. 496 (the Land Registration Act). As settled jurisprudence holds, registered land cannot be acquired by prescription or adverse possession. Thus, MCIAA’s claim of acquisitive prescription, whether ordinary or extraordinary, fails. Its possession, however long, did not ripen into ownership over the respondents’ shares.
Furthermore, respondents’ right of legal redemption under Article 1620 of the Civil Code was not extinguished. This provision allows co-owners to redeem a sold share within one month from written notice of the sale. Critically, the heirs of Tito Dignos never provided such written notification to the other co-owners. Therefore, the one-month redemption period never commenced, preserving respondents’ redemption right. The Court noted that this decision is without prejudice to MCIAA seeking redress against the vendors (heirs of Tito Dignos) for breach of warranty. The action was not barred by laches, as respondents’ possession was only disturbed in 1996, prompting their timely suit.