G.R. No. L-44841. January 27, 1986.
CIPRIANO E. SAMONTE, ET AL., petitioners, vs. THE HONORABLE COURT OF APPEALS, BENILDA C. ACOSTA, and SALVADOR C. ACOSTA, respondents.

FACTS

The petitioners, heirs of Placida Espiritu, sought to recover three parcels of rice land in Dingras, Ilocos Norte. They alleged that in 1930, Placida merely transferred possession of the lands (part of five original parcels) to Victoria Mendoza by way of an oral contract of antichresis, not an absolute sale. Victoria died in 1937, and succession eventually vested the property in the private respondents, the Acostas. The petitioners claimed ownership as heirs, arguing the antichretic agreement entitled them to recover the property.
The private respondents asserted ownership by purchase, presenting documentary evidence that Benilda Mendoza, Victoria’s sister and predecessor-in-interest, had executed an affidavit claiming ownership as early as May 23, 1947, and again in 1952. The petitioners filed their complaint for recovery on April 3, 1970. The trial court dismissed the complaint, ruling that the private respondents had acquired title through ordinary acquisitive prescription, having possessed the property in the concept of an owner for over ten years from Benilda’s open claim of ownership in 1952, without any judicial summons to interrupt that possession.

ISSUE

Whether the private respondents have acquired ownership over the disputed property through acquisitive prescription and whether the petitioners’ claim is barred by laches.

RULING

The Supreme Court affirmed the Court of Appeals’ decision, upholding the private respondents’ ownership. The legal logic rests on two primary grounds: acquisitive prescription and the presumption of just title under Article 541 of the Civil Code. First, the Court clarified that the ten-year period for ordinary acquisitive prescription commenced from May 23, 1947, when Benilda Mendoza executed a sworn affidavit (Exhibit “7”) openly asserting ownership. No judicial summons was served upon Benilda or her successors prior to the filing of the 1970 case; thus, their possession, public, peaceful, and in the concept of an owner, remained uninterrupted. By the time the suit was filed, more than two decades had elapsed, perfecting the Acostas’ title by prescription.
Second, the Court applied Article 541, which creates a legal presumption that a possessor in the concept of an owner possesses with a just title. The burden to rebut this presumption lay with the petitioners. Their claim of an oral antichresis in 1930, supported only by testimonial evidence, was deemed legally insufficient to overcome the presumption and the documented acts of ownership by the respondents’ predecessors. Furthermore, the Court found the petitioners guilty of laches. Their inaction from 1941 (when the alleged loan under the antichresis would have been fully paid) until 1970, a period of nearly thirty years, while the respondents and their predecessors openly possessed and claimed the land, rendered their belated claim inequitable and unbelievable. The combination of perfected acquisitive prescription, the statutory presumption of just title, and laches conclusively vested ownership in the private respondents.