GR L 2241; (April, 1906) (Digest)
G.R. No. L-2241
FACTS:
Plaintiffs-appellants Prudencia del Rosario and her husband sought to recover possession of a tract of land from defendants-appellees Severina Lerma and her husband, along with damages. The appellants claimed ownership through inheritance and alleged possession for about seventy-five years. The appellees had previously obtained a final and executory judgment of ejectment against Prudencia del Rosario from the justice of the peace court for non-payment of rent, which she did not appeal. The Court of First Instance found that the appellants’ possession was not as owners but as mere tenants under written contracts of lease executed with Jose Lerma, the father of Severina Lerma. Furthermore, the appellees presented documentary evidence establishing their registered title to the land, acquired by Jose Lerma from the Dominican Friars and the Spanish Government, and subsequently inherited by Severina Lerma.
ISSUE:
Whether the Court of First Instance erred in dismissing the appellants’ complaint for recovery of possession and ownership of the land.
RULING:
No, the Court of First Instance did not err. The Supreme Court affirmed the dismissal of the complaint. The appellants failed to substantiate their claim of ownership. Their possession was conclusively shown to be that of a lessee or tenant under contracts with the true owner, Jose Lerma. Possession as a tenant, regardless of its duration, cannot ripen into ownership by prescription because such possession is not adverse or under a claim of ownership. The appellees’ title, derived from valid acquisition and duly registered, was firmly established. The appellants’ dispossession was lawful, having been effected by virtue of a final judgment in an ejectment case for non-payment of rent. Consequently, the appellants were not entitled to recover possession or ownership, and the temporary injunction issued in their favor was properly lifted.
