G.R. No. 46753-54 August 25, 1989
ANTONIO SOLIS and ANGELA SOLIS CALIMLIM, petitioners, vs. HONORABLE COURT OF APPEALS, JOSE SOLIS and FLORENCIA DIOQUINO, respondents.

FACTS

Petitioners Antonio Solis and Angela Solis Calimlim filed a complaint for recovery of possession and ownership against respondents Jose Solis and Florencia Dioquino over a 536-square-meter eastern portion of an unregistered residential lot in Calasiao, Pangasinan. Petitioners claimed co-ownership by inheritance from their father, Simeon Solis, and alleged they merely permitted respondents to build a house on the land in 1939 under the understanding they would vacate when financially able. Upon petitioners’ demand to vacate in 1965, respondents refused. Respondents asserted ownership, presenting a 1931 donacion proper nuptias from Tomas Solis (Jose’s father and Simeon’s nephew) and claiming open, continuous, and adverse possession since 1931, including tax payments.
The trial court ruled for petitioners, declaring Antonio Solis the exclusive owner. It found that while respondents possessed the land for over 30 years, such possession could not be adverse against petitioners who showed a better title derived from Simeon Solis. The court emphasized respondents’ predecessor, Tomas Solis, had no proven title to donate, as there was no evidence Simeon conveyed the portion to him. Thus, respondents acquired no rights, and prescription did not apply.

ISSUE

Whether respondents have acquired ownership of the disputed property through acquisitive prescription.

RULING

Yes. The Supreme Court affirmed the Court of Appeals’ reversal, holding that respondents acquired ownership by ordinary acquisitive prescription under the Old Civil Code. The Court clarified that petitioners’ cause of action accrued in 1933 when respondents took possession under the donation, which constituted a repudiation of petitioners’ ownership. Even assuming the cause of action accrued later in 1941—when respondents first paid property taxes in Jose Solis’s name—prescription had still run. Respondents’ possession was actual, open, continuous, peaceful, and adverse for over thirty years, far exceeding the ten-year period required under Section 41 of the Old Civil Code.
Applying Article 1116 of the New Civil Code, prescription that began before its effectivity is governed by prior laws. Therefore, the ten-year prescriptive period under the Old Civil Code controlled. Respondents’ uninterrupted adverse possession for at least twenty years (from 1941 to 1967 when the suit was filed) vested in them a complete title. The Court rejected petitioners’ argument on the invalidity of the donation due to Tomas Solis’s lack of title, as the issue was rendered moot by the superior legal effect of acquisitive prescription. Respondents’ long-standing adverse possession extinguished any claim of petitioners.