G.R. No. L-2468

FACTS:
Plaintiff Magdalena Cansino acquired the subject land from the Spanish Government as public land, receiving a deed on October 27, 1893. Defendants, who had been in possession of the land since around 1862, claimed ownership by virtue of extraordinary prescription of thirty (30) years. They had no written title to the property.

ISSUE:
Can title to public lands of the State be acquired by prescription while the lands remain property of the State?

RULING:
No. The Supreme Court, citing its prior ruling in Valenton v. Murciano (3 Phil. 537), held that title to lands which are property of the State cannot be acquired through prescription. Since the defendants’ claimed period of possession commenced and continued while the land was still public domain of the Spanish Government (and later the Philippine State), their acquisitive prescription could not run against the State. The decision in Valenton was controlling. Accordingly, the judgment in favor of the plaintiff-appellee was affirmed.