GR L 14852; (August, 1964) (Digest)
G.R. No. L-14852. August 21, 1964.
TEODOSIA NATIVIDAD and RUFINO POQUIZ, plaintiffs-appellants, vs. MARCELIANO NADAL, TOMAS NADAL, FILEMON NADAL and ISABELO MENDOZA, defendants-appellees.
FACTS
The plaintiffs-appellants, Teodosia Natividad and Rufino Poquiz, sought to recover possession of a parcel of land designated as Lot No. 34. Their claim was based on a Certificate of Title issued under a homestead patent in the name of Mariano Natividad, Teodosia’s father. However, the land was originally part of a registration proceeding by Antonia Tamondong, wherein the defendants-appellees, the Nadals, successfully opposed the application for Lot No. 34. The Court of Land Registration declared the Nadals as the owners of Lot No. 34 and excluded it from Tamondong’s certificate. Consequently, a notation on the back of Mariano Natividad’s Certificate of Title No. 1633 stated that Lot No. 34 belonged to Marceliano Nadal. The parties stipulated that since 1942, the plaintiffs had taken possession of Lot No. 34 based on their grandfather’s title and had been in continuous, exclusive, and adverse possession as owners, enjoying its products despite opposition from the defendants.
ISSUE
Whether the plaintiffs-appellants acquired ownership of Lot No. 34 through acquisitive prescription (adverse possession) despite the prior judicial decree declaring the defendants-appellees as the owners.
RULING
Yes. The Supreme Court granted the motion for reconsideration and set aside its original judgment. The Court clarified that the patent issued to Mariano Natividad could not confer title over Lot No. 34, as it was already declared private land owned by the Nadals in prior registration proceedings. The notation on the back of Natividad’s title was merely an annotation and did not constitute a new decree of registration. Critically, the prior decree from the Court of Land Registration, which recognized the Nadals’ ownership, was akin to a judgment in an action to quiet title. Such a judgment does not extinguish the possibility of another party acquiring title through adverse possession under Section 41 of the Code of Civil Procedure (Act No. 190). Since the stipulation of facts established that the plaintiffs and their predecessor-in-interest had been in open, continuous, exclusive, and adverse possession of the land for over ten years (since 1942), they acquired title through ordinary acquisitive prescription. The case was remanded to the trial court for further proceedings to fully adjudicate the matter based on this principle.
