G.R. No. 6327 , September 11, 1911
MANZANO MASSAOAY, plaintiff-appellant, vs. ESTEBAN BLASI, defendant-appellee.

FACTS

Plaintiff Manzano Massaoay filed a suit to recover a parcel of land from defendant Esteban Blasi. Massaoay claimed ownership based on a composition title issued by the State on July 26, 1898. The trial court ruled in favor of Blasi, finding that Massaoay had abandoned the land and that Blasi had subsequently occupied, cleared, and cultivated it continuously for many years with permission from the local gobernadorcillo. The lower court inferred abandonment from Massaoay’s failure to collect his share of the harvest after 1901 and his delay in filing suit until 1909.

ISSUE

Whether the plaintiff had abandoned his ownership of the land, thereby justifying the defendant’s possession.

RULING

No. The Supreme Court reversed the trial court’s decision. The Court held that:
1. Massaoay’s ownership was duly established by the composition title of July 26, 1898.
2. There was no evidence of abandonment or renunciation of ownership. The failure to collect rent or file suit promptly did not constitute abandonment; it merely indicated negligence in safeguarding his interests, not an intention to relinquish ownership.
3. The defendant’s claim of permission from the gobernadorcillo in 1885 was irrelevant because Massaoay did not own the land at that time. Moreover, the authorization did not specifically refer to the sitio where the land was located and was superseded by the State’s subsequent grant to Massaoay.
4. Prescription was not invoked and, in any case, the required period had not elapsed.

The Court ordered Blasi to restore the land to Massaoay. Costs in the first instance were charged to Blasi, with no special costs on appeal.