G.R. Nos. L-18099 and L-18136; July 31, 1962
MARIANO CORPUZ, petitioner, vs. BENJAMIN PADILLA, respondent.

FACTS

Mariano Corpuz filed a forcible entry case against Benjamin Padilla over a parcel of land in Laur, Nueva Ecija. The Justice of the Peace Court ruled in favor of Corpuz, ordering Padilla to vacate and pay rentals. Padilla appealed to the Court of First Instance (CFI). Pending this ejectment case, Padilla applied for the land’s registration under the Torrens system. The CFI ordered a consolidated hearing of the registration case and the appealed ejectment case. Padilla traced his claim from Sixto Domingo to Pedro Domingo, from whom he purchased the land in 1956. Corpuz, opposing the application, claimed ownership through his father, Mariano Corpuz, Sr., alleging possession since 1925 and presenting a 1937 deed of sale (Exhibit 1) executed by Pedro Domingo in favor of Corpuz, Sr.
The CFI dismissed Corpuz’s opposition and ordered the land’s registration in Padilla’s name. The court interpreted Exhibit 1 as Corpuz, Sr.’s recognition that Lot 4 belonged to Pedro Domingo, with the sale covering only a two-hectare portion that was allegedly within Corpuz, Sr.’s already titled property (Lot 2), not the entirety of Lot 4. The Court of Appeals affirmed this decision, prompting Corpuz’s appeal to the Supreme Court.

ISSUE

The core issue is whether the 1937 deed of sale (Exhibit 1) conveyed ownership of the entire Lot 4 to Mariano Corpuz, Sr., or merely recognized Pedro Domingo’s ownership of Lot 4 while transferring only a specific two-hectare portion within Corpuz’s titled land.

RULING

The Supreme Court affirmed the lower courts’ decisions, denying Corpuz’s claim and upholding Padilla’s registration. The legal logic centered on the unambiguous interpretation of the 1937 deed. The Court held that the document clearly showed Mariano Corpuz, Sr. recognized Lot 4 as belonging to Pedro Domingo. The sale transferred only the two-hectare portion of land, which Pedro Domingo was claiming, that was already included within the boundaries of Corpuz, Sr.’s titled property (Lot 2). It did not constitute a sale of the entirety of Lot 4. This interpretation was bolstered by the fact Corpuz, Sr. had no title to Lot 4.
Consequently, Corpuz’s alternative claim of acquisitive prescription over Lot 4 failed. The Court ruled that one cannot claim adverse possession for prescription when one’s predecessor-in-interest had expressly recognized another’s ownership in a public document. Prescription requires adverse, continuous, and exclusive possession, which is negated by such an acknowledgment. Since Pedro Domingo’s ownership of Lot 4 was recognized in 1937, and he validly sold it to Padilla in 1956, Padilla had a registrable title. The Supreme Court found no reversible error in the lower courts’ factual findings and legal conclusions.