G.R. No. 38709, December 14, 1933
Sy Tiangco vs. Hipolito Pablo and Federico Apao

FACTS

Plaintiff Sy Tiangco filed an action to recover possession of nine parcels of land. He later withdrew his claim for two parcels. Defendant Hipolito Pablo claimed he purchased four of the remaining parcels from the plaintiff in 1901, as evidenced by a notarized deed of sale, and had possessed them openly as owner for over twenty years, improving the land, paying taxes, and settling boundary disputes. Sy Tiangco denied the sale, alleged the deed was a forgery, and claimed Pablo was merely his employee or overseer who managed the land and delivered a share of the produce.

ISSUE

Whether Hipolito Pablo has a better right to the possession of the disputed parcels of land, either by virtue of a valid purchase or by acquisitive prescription (adverse possession).

RULING

Yes. The Supreme Court affirmed the dismissal of the complaint and upheld Pablo’s better right to possession. The plaintiff’s denial of his signature on the notarized deed of sale was insufficient to overcome the document’s presumption of regularity. Furthermore, Pablo had acquired title by acquisitive prescription (adverse possession). His open, continuous, exclusive, and notorious possession of the land under a claim of ownership for over twenty-three years—coupled with acts of ownership like paying taxes and making improvements—vested ownership in him. The plaintiff’s evidence to prove a mere overseer or tenancy relationship was deemed vague and improbable.

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