G.R. No. 18006 ; September 27, 1922
THE ROMAN CATHOLIC BISHOP OF TUGUEGARAO, applicant-appellant, vs. THE MUNICIPALITY OF APARRI, objector-appellee.

FACTS

The Roman Catholic Bishop of Tuguegarao applied for the registration of a parcel of land in Aparri, Cagayan, which had once been occupied by a Catholic church. The Municipality of Aparri opposed, claiming ownership by acquisitive prescription. In 1898, revolutionary forces ejected the parish priest and turned the property over to municipal authorities. By 1899, a tenant began paying rent to the municipality, which continued until 1904 when the municipality took full possession, using the land as a municipal ferry landing. The municipality exercised open, continuous, and adverse possession for over ten years before the registration petition was filed. In 1903 or 1904, the Church, through its priest, made a written demand for the property’s return, which the municipality ignored.

ISSUE

Whether a municipality can acquire title to land by acquisitive prescription against a private owner.

RULING

Yes. The Supreme Court affirmed the denial of the Church’s application and recognized the municipality’s acquisitive title. The Court distinguished prior cases where municipalities could not acquire title by prescription against the sovereign state (the Insular Government) over public lands. Here, the land was privately owned by the Church before the municipality’s adverse possession began. A municipality, like any juridical person, can acquire property through prescription for legitimate municipal purposes under the Administrative Code. The municipality’s open, adverse, and uninterrupted possession as owner for over ten years (from at least 1904) vested title in it. The property is held as patrimonial property. The Church’s prior ownership was extinguished by prescription.