G.R. No. 29522 , January 23, 1929
FELIPE PALENCIA, as administrator of the estate of Maria Palencia, plaintiff-appellant, vs. IRENE JAUCIAN DE DEL ROSARIO, ET AL., defendants-appellees.

FACTS

Felipe Palencia, as administrator of the estate of Maria Palencia, filed an action for ejectment against Irene Jaucian de Del Rosario and her husband. The defendants claimed ownership over the land, alleging that Irene’s first husband, Ricardo Lopez, purchased it in good faith in 1913 from Bernabea Orzales, the administratrix of Maria Palencia’s estate, with court authorization. After Ricardo’s death, half of the land was donated to their daughter, Remedios Lopez. The defendants and their predecessor had been in open, continuous, and adverse possession of the land since the 1913 sale. The trial court ruled in favor of the defendants, declaring that they had acquired title by prescription.

ISSUE

Whether the defendants acquired ownership of the land through acquisitive prescription, despite the land being sold by an estate administratrix, and whether the statute of limitations applies against the estate’s administrator.

RULING

Yes. The Supreme Court affirmed the trial court’s decision, holding that the defendants acquired title by prescription under Section 41 of the Code of Civil Procedure.

The Court rejected the appellant’s argument that the estate administration constituted a “continuous and subsisting trust” under Section 38 of the Code of Civil Procedure, which would suspend the running of the statute of limitations. Citing American jurisprudence, the Court clarified that an administrator, while a fiduciary, is not a trustee in the technical sense used in equity statutes. Therefore, the general statute of limitations applies to attacks against an administrator’s sale.

Since the defendants and their predecessor-in-interest purchased the land in good faith and had been in open, continuous, exclusive, and adverse possession for more than the statutory period (since 1913), they acquired ownership through ordinary acquisitive prescription. The Court deemed it unnecessary to address other issues raised by the appellant.