G.R. No. L-10031
December 6, 1915
LA CORPORACION DE PADRES AGUSTINOS RECOLETOS, plaintiff-appellant, vs. PEDRO CRISOSTOMO, ET AL., defendants-appellants.

FACTS:
The plaintiff, La Corporacion de Padres Agustinos Recoletos, filed an action to recover possession of several parcels of land, alleging ownership. The trial court ruled in favor of the plaintiff for some parcels and against it for others. The defendants who prevailed claimed ownership through prescription or adverse possession. The trial court sustained this defense based on the evidence. The plaintiff appealed the decision regarding the parcels it did not recover. Some defendants specifically pleaded title by adverse possession, while others only entered a general denial. The plaintiff argued that evidence of adverse possession was inadmissible under a general denial and must be specially pleaded.

ISSUE:
Whether evidence of title by adverse possession to real property may be admitted under a general denial in an action for recovery of possession.

RULING:
Yes. The Supreme Court affirmed the trial court’s judgment. The Court distinguished between prescription that merely bars an action (extinctive prescription) and prescription that transfers title (acquisitive prescription). Under the Code of Civil Procedure, adverse possession of real property for the required period (ten years) confers a “full and complete title” upon the possessor (Section 41). This operates as a direct denial of the plaintiff’s title, not merely as a bar to the remedy. Therefore, evidence of such adverse possession is admissible under a general denial, as it goes to the very issue of the plaintiff’s ownership. The Court clarified that prior decisions requiring the statute of limitations to be specially pleaded involved personal property or extinctive prescription, not title by adverse possession to real property. However, this rule does not apply to land registered under the Land Registration Act, where title cannot be acquired by prescription against the registered owner.