G.R. No. L-4868
JUAN SISON, plaintiff-appellant, vs. FAUSTINO RAMOS, defendant-appellee.
February 24, 1909

FACTS:
On August 24, 1906, Juan Sison (plaintiff) filed a complaint against Faustino Ramos (defendant), alleging that Sison owned a 94-hectare tract of land (Hacienda Antipolo) in Sagay, Occidental Negros, which he acquired from Mariano Devesa, who in turn acquired it from Pedro Catalbas (original title holder). Sison claimed that Ramos, Catalbas’ brother-in-law, occupied a 5-hectare parcel within this tract by mere tolerance. In May 1905, Sison requested Ramos to vacate, but Ramos refused, claiming ownership. Sison sought restoration of the parcel and P850 in damages for lost fruits and profits.

Ramos denied Sison’s allegations, claiming exclusive and absolute ownership of the parcel (which he stated was about 3 cavanes) and its improvements. He asserted that he had been in quiet, peaceful, and uninterrupted possession of the land since 1884, having purchased it from the original owners, Constantina Gereos and Raymundo Lobaton, as evidenced by private documents A and B.

The trial court ruled in favor of Ramos, holding that the parcel belonged to him and absolving him from the complaint. Sison’s motion for a new trial was denied, leading to this appeal.

ISSUE:
Whether Juan Sison proved his right of ownership over the disputed parcel of land against Faustino Ramos’s claim of ownership by purchase and prescription.

RULING:
The Supreme Court affirmed the judgment of the trial court, ruling in favor of Faustino Ramos.

The Court held that for an action for recovery to prosper, the plaintiff must fully prove both his dominion over the thing claimed and its identity. Sison failed to satisfactorily substantiate his claim.

Conversely, the evidence showed that Ramos acquired the parcel in two portions in 1884 from the original owners, Constantina Gereos and Raymundo Lobaton, through documents A and B, whose authenticity was proven by witnesses. Ramos had been in peaceful, public, and uninterrupted possession as owner for more than twenty-one years (since 1884).

The Court found that even assuming Sison’s predecessors (Catalbas) were the owners, Ramos had acquired ownership by prescription through possession for more than twenty years with good faith and a just title (his purchases). The fact that Ramos’s acquisition documents were merely private documents was not a bar to their consideration as a just title. Citing Alano vs. Babasa (10 Phil Rep., 511) and a decision from the Supreme Court of Spain, the Court reiterated that a contract with the essential requisites is valid and binding between the parties, even if not in a public instrument or recorded in the registry; such formal requirements are for validity against third persons, not between the contracting parties.

Furthermore, the Court stated that the inclusion of the parcel in Pedro Catalbas’s composicion title did not prejudice Ramos’s rights, especially since Catalbas’s own son, acting as attorney-in-fact, had acknowledged Ramos’s ownership of the included parcel. Lastly, the Court clarified that Articles 1949 of the Civil Code and 35 of the Mortgage Law, concerning prescription and third persons, do not consider the lawful owner of the property as a “third person.” Prescription to the prejudice of the owner is counted from the commencement of possession under title of ownership, even if the title was not registered. As Sison’s own title was not recorded, he could not be considered a third person under the Mortgage Law.