Wednesday, December 2, 2020

Heirs of Placido Miranda v. CA [G.R. No. 109312] Case Digest

 

Heirs of Placido Miranda v. CA

G.R. No. 109312

 

Facts:

Placido Miranda and his wife were owners of a parcel of land, in Pawa-Talon and Guintoan, Palauig, Zambales. Upon their death, the land was administered by their son Maximo Miranda.  Maximo sold the land to Agerico Miranda.  OCT was issued to Agerico Miranda's daughter, Charito. Agerico Miranda has been in possession and cultivation of the land in behalf of his daughter, now a resident of New Jersey, U.S.A.

The heirs of Placido Miranda entered the land and prevented private respondents (Agerico Miranda) from cultivating it, claiming that they were the rightful owners and possessors because Maximo Miranda was merely the administrator of Placido's estate.

Agerico Miranda brought an action for forcible entry in the Municipal Circuit Trial Court. The complaint was dismissed by the court on the ground that it had no jurisdiction over the case, but on appeal the RTC at Iba, Zambales reversed and remanded the case to the MCTC.

MCTC rendered judgment for private respondents, ordering petitioners to vacate the land. RTC affirmed in toto the decision MTCC. CA reversed the decision of RTC. Petitioners herein filed a complaint for Declaration of Nullity, Annulment of Title and Deed of Sale and Cancellation of Title and Reconveyance with Damages and Partition against private respondents.

Respondents alleged that since 1957, they had been in possession and cultivation of the land, planting it to mango and coconut trees. After Charito Miranda had gone to the U.S.A., the land was administered by her father, Agerico Miranda. Upon motion of private respondents, the Regional Trial Court dismissed the complaint on the ground of prescription.

 

Issue:

Whether or not Agerico Miranda (Respondent) acquired the land by prescription.

 

Held:

Yes.

 

Ratio:

Ownership and other real rights over immovable property are acquired by ordinary prescription through possession for ten years if the adverse possession is by virtue of a title and it is in good faith.  Without need of title or of good faith, ownership and other real rights over immovable also prescribe through uninterrupted adverse possession for 30 years.  For possession to constitute the foundation of a prescriptive right, it must be under a claim of title or it must be adverse or in the concept of owner.  In this case, therefore, on the basis alone of possession for more than 30 years, private respondents' ownership, acquired through extraordinary prescription, is beyond question.

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