G.R. No. L-2720

FACTS:
Compañia Agricola de Ultramar, a duly established civil partnership, filed a petition for the registration of the Hacienda de Mandaloyon under the Land Registration Act. It derived its title from a sale in 1893 by the religious order “Provincia del Santisimo Nombre de Jesus de Agustinos Calzados,” which had previously registered the property in 1891. The company presented documentary evidence, including certificates from the registry and copies of recorded titles, to support its claim of ownership. Several individuals, led by Marcos Domingo, opposed the registration, asserting ownership over various portions of the hacienda based on alleged titles by inheritance, donation, or prescription through long possession. The trial court ruled in favor of the petitioner, finding the oppositions to be vague, contradictory, and unsupported by competent evidence. The oppositors appealed.

ISSUE:
Whether the trial court erred in granting the petition for registration and in rejecting the oppositors’ claims of ownership.

RULING:
No, the trial court did not err. The Supreme Court affirmed the decision in its entirety.
1. On Petitioner’s Title: The petitioner presented competent and conclusive documentary evidence establishing its chain of title from the original grantee, the Spanish Government, through the religious order, and finally to itself via a recorded deed of sale. This evidence was sufficient to vest ownership.
2. On the Oppositors’ Claims: The claims of the oppositors were correctly rejected by the trial court. Their evidence consisted merely of recent tax declarations (which are not proof of ownership) and incoherent, contradictory testimonial evidence. Their alleged titles by inheritance or donation were not properly established and were feebly supported.
3. On Prescription: The claim of acquisitive prescription failed. For ordinary prescription, the oppositors did not prove possession with just title and good faith. For extraordinary prescription, while they alleged long possession, they failed to prove the essential element of possession under a claim of ownership ( animus domini ). The Court held that mere physical possession is compatible with and can be subordinate to the juridical possession and ownership of another, such as that of a lessor. The petitioner, in fact, presented strong evidence (e.g., lease contracts, acts of dominion, recognition by the municipality and the oppositors themselves) that the oppositors’ possession was merely by tolerance or under lease agreements, not adverse.
4. On the Nature of the Opposition: The Court noted that a successful opposition would require the oppositor to have a registrable title themselves. None of the oppositors met this burden of proof.

The petition for registration was granted, and the oppositions were dismissed. Costs were taxed against the appellants.