G.R. No. L-7333; March 18, 1913
AQUILINA and DEMETRIO ARCENAS, plaintiffs-appellees, vs. ESTANISLAO LASERNA, defendant-appellant.

FACTS

Aquilina and Demetrio Arcenas filed a complaint for recovery of possession against Estanislao Laserna, alleging ownership of a parcel of land in Capiz which they purchased from Josefa Jabar in September 1910. They claimed that in December 1910, Laserna illegally fenced and occupied a portion of said land, approximately 207 square meters. Laserna denied the allegations, asserting exclusive ownership and possession of the disputed portion for over ten years as owner, plus the possession of his predecessors. He presented as evidence a recorded possessory information title (Exhibit 1) obtained by his mother, Casiana Alvarez, in 1895 over a 207-square-meter lot with boundaries matching the disputed land, and a receipt for its inscription (Exhibit 2). The Arcenases presented a composition title (Exhibit B) issued in 1891 to Matea Alvarez y Rubio for a larger tract (24 ares and 63 centares), and a deed of sale (Exhibit A) from Josefa Jabar (who acquired it from Matea Alvarez’s estate) covering that larger tract. The trial court ruled in favor of the Arcenases, ordering Laserna to restore possession. Laserna appealed.

ISSUE

Whether the defendant, Estanislao Laserna, has a superior right of ownership over the disputed 207-square-meter portion of land.

RULING

Yes. The Supreme Court reversed the trial court’s judgment and absolved Laserna from the complaint. The Court held that Laserna’s recorded possessory information title, acquired by his mother and inherited by him, constitutes prima facie proof of ownership under established jurisprudence. This title was not overcome by the plaintiffs’ evidence. The composition title and deed presented by the Arcenases described a larger tract but did not specifically prove that the disputed 207-square-meter lot was included within its boundaries. Furthermore, the Court found that Laserna and his predecessors had possessed the land openly, peacefully, and as owners for the required period, such that ownership would have prescribed in his favor. Therefore, Laserna has a superior right to the property.