G.R. No. 5730: REGINO SALACUP, plaintiff-appellant, vs. SOTERO RAMBAC, defendant-appellee.
September 9, 1910
FACTS:
Regino Salacup filed a complaint in the Court of First Instance of Ilocos Norte, claiming ownership of a rural property by virtue of quiet, peaceful, and uninterrupted possession for over thirty years, supported by a possessory information title recorded on March 27, 1895. He alleged that Sotero Rambac had been arbitrarily and illegally detaining a portion of his land (from its southern side) for the past five years. This disputed portion measured 202 meters in perimeter and produced palay annually, for which Salacup sought P55.50 in damages.
Rambac denied Salacup’s allegations, claiming to be the true owner of the property and asserting possession for more than twenty years.
The Court of First Instance found Salacup’s complaint unsubstantiated and absolved Rambac. Salacup appealed. During the trial, an ocular inspection was conducted by the deputy sheriff, at the request of Rambac’s attorney. The inspection report, agreed upon by both parties’ attorneys, concluded that the 202-meter parcel of land held by Rambac was included within Salacup’s larger 438-meter land, specifically in its southern part, and matched the description in Salacup’s possessory information and complaint.
ISSUE:
Did the plaintiff, Regino Salacup, sufficiently prove his ownership and the identity of the disputed land to warrant its recovery from the defendant, Sotero Rambac, in an action for recovery of title (accion reivindicatoria)?
RULING:
Yes. The Supreme Court reversed the judgment of the lower court.
The Court held that for an action for the recovery of title to prosper, the plaintiff must fully prove both his ownership of the thing claimed and its identity.
1. Ownership: Salacup successfully proved his ownership by presenting a certified copy of a possessory information title, duly recorded in the registry of property in 1895, which was neither impugned nor assailed. The Court reiterated that a possessory information title recorded in the registry is prima facie proof that the possessor is the owner thereof.
2. Identity: The identity of the land unlawfully held by Rambac was conclusively proven by the ocular inspection report. This report, made pursuant to a court order and agreement by both litigants, clearly showed that the smaller parcel of land (202 meters perimeter) held by Rambac was situated within and formed part of Salacup’s larger property (438 meters perimeter), as described in Salacup’s complaint and possessory information.
The Court found that Rambac, on the other hand, failed to substantiate his claim of ownership. Therefore, Rambac was considered an unlawful holder without title or good reason, and could not be deemed an owner in good faith.
Accordingly, the Supreme Court declared Regino Salacup the owner of the disputed land and condemned Sotero Rambac to restore the unlawfully held portion of the land to Salacup, along with the proven damages of 5 uyones, 5 baares, and 5 manojos of palay, or their cash value of P55.50.