G.R. Nos. 30850, 30851 & 30852, September 6, 1929
CASIMIRO MANUEL, Plaintiff-Appellant, vs. JOSE CASTILLO, Defendant-Appellee.

(Consolidated Cases: Land Registration and Recovery of Ownership)

FACTS

Three cases were consolidated concerning a 75-hectare parcel of land (Lot 3). Casimiro Manuel claimed ownership, alleging he purchased the land from the children of Rosendo Bueno and that Jose Castillo had previously offered to buy it from him. Jose Castillo, on the other hand, claimed ownership by inheritance from his father, Adolfo Castillo, and asserted that he had been in open, continuous, adverse, and public possession of the land since 1900. The trial court ruled in favor of Castillo, dismissing Manuel’s claims and application for registration, and instead decreeing the land in favor of Castillo, subject to a municipal right of way. Manuel appealed.

ISSUE

1. Whether Jose Castillo’s alleged offer to purchase the land from Casimiro Manuel was proven.
2. Whether Casimiro Manuel’s ownership of the land was established.
3. Whether the trial court erred in adjudicating the land in favor of Jose Castillo and dismissing Manuel’s opposition.
4. Whether the defense of prescription under Section 41 of the Code of Civil Procedure is applicable in favor of Castillo, despite his possession beginning before the Code’s effectivity.

RULING

The Supreme Court AFFIRMED the trial court’s judgment in all respects.
1. No, the alleged offer to purchase by Castillo was not sufficiently proven. The Court found Castillo’s testimony credible that he refused an offer to buy the land upon discovering it was his own, and such an offer was inconsistent with his conduct of asserting ownership.
2. No, Manuel’s claim of ownership was not proven. The evidence preponderated in favor of Castillo. It was established that Castillo inherited the land from his father and had possessed it publicly, continuously, and adversely as owner since 1900.
3. No, the trial court did not err. Given the findings on possession and ownership, the adjudication in favor of Castillo was correct.
4. Yes, the defense of prescription under Section 41 of the Code of Civil Procedure was applicable. The Court rejected Manuel’s argument that the Code could not apply because Castillo’s possession began in 1900, before the Code’s enactment. Citing Section 38 and proviso of the same Code, as well as prior jurisprudence (Jones v. Insular Government and Balpiedad v. Insular Government), the Court held that the prescriptive period applied, and all rights of action (except for continuing trusts or actions by a vendee in possession) had to be vindicated within ten years after the Code took effect. Manuel’s action was therefore barred.

The ownership and registration of the land were rightfully awarded to Jose Castillo.