G.R. No. L-8703, October 26, 1916
NAZARIO MARCELO, plaintiff-appellee, vs. CLEMENCIA MANIQUIS and JUAN DE LA CRUZ, defendants-appellants.

FACTS:
Plaintiff Nazario Marcelo filed an action in the Court of First Instance of Nueva Ecija to recover possession of a parcel of land located in the sitio of Tañgos, barrio of Soledad, Santa Rosa, Nueva Ecija. He alleged exclusive ownership based on a possessory information title registered in 1896 and tax declarations and payments from 1902 to 1911. He claimed that in July 1911, defendants Clemencia Maniquis and Juan de la Cruz unlaw appropriated a portion of his land measuring 2½ cavanes of seed.

Defendants denied Marcelo’s ownership and asserted that Clemencia Maniquis and her late husband, Mariano del Barrio, had been in quiet, public, and uninterrupted possession of the disputed land for over thirty years. They presented a deed of sale dated 1893, wherein Potenciano Marcelo (plaintiff’s nephew) sold the land to Mariano del Barrio, and a possessory information title obtained by del Barrio in 1895 (registered in 1911). They argued that the land was the only property owned by del Barrio in that locality.

The trial court ruled in favor of Marcelo, ordering defendants to restore the land, pay damages for lost products, and cover survey costs. Defendants appealed.

ISSUE:
Who is the true owner of the disputed parcel of land?

RULING:
The Supreme Court REVERSED the trial court’s decision and ABSOLVED the defendants from the complaint.

The Court held that in an action for recovery of possession (accion reivindicatoria), the plaintiff must conclusively prove both ownership and the identity of the property claimed. Marcelo failed to meet this burden. His possessory information title described a parcel with boundaries differing from those of the land held by defendants. Specifically, the land in the defendants’ title was bounded on the north by Obdulia Punsal’s land (which was adjacent to Marcelo’s property on the west), while Marcelo’s title described different adjacencies. The evidence showed that Mariano del Barrio had only one parcel in the area, which matched the description in his possessory information title and the deed of sale from Potenciano Marcelo. Furthermore, Marcelo had been notified of del Barrio’s possessory information proceedings in 1895 and raised no objection at that time.

Thus, Marcelo did not satisfactorily prove ownership of the specific land held by defendants, nor did he demonstrate prior possession thereof. The defendants’ title and long possession remained uncontroverted.