Primary Holding

An invalid donation of immovable property, while not transferring title, can serve as a valid basis for acquisitive prescription if accompanied by open, continuous, adverse, and public possession in the concept of owner for the period required by law.

Background

The case stemmed from a partition action where plaintiffs claimed common ownership of land and sought damages for lost profits. The defendant asserted sole ownership based on a donation propter nuptias received in 1906 and his subsequent adverse possession for over 40 years, arguing for prescription and lack of cause of action for partition.

Facts

• 1. Plaintiffs and Defendant are children of Basilio Espique and Maria Diaz.
• 2. Julian Espique, grandfather to plaintiffs and defendant, along with Basilio Espique and Maria Diaz, purportedly donated lands propter nuptias to Defendant and his wife in a private document dated May 8, 1906.
• 3. Defendant and his wife possessed and enjoyed the lands adversely and without interruption from 1906 to 1949.
• 4. Plaintiffs filed for partition in 1949, claiming common ownership and damages for unenjoyed profits from 1916-1949.
• 5. Parties stipulated that the donation was made in a private document.
• 6. Plaintiffs admitted in their complaint the defendant's possession and appropriation of produce since 1916.

Arguments of the Petitioners

• 1. The donation propter nuptias is void because it was not in a public document as required by law for immovable property donations.
• 2. An invalid donation cannot transfer title or serve as a valid foundation for acquisitive prescription.
• 3. There is insufficient evidence to prove continuous, public, open, and adverse possession by the defendant for the required prescriptive period.

Arguments of the Respondents

• 1. N/A. Respondent's arguments are implied through the lower court's ruling which he defended. The core argument is that the donation, though invalid as a transfer of title, provided a basis for adverse possession, leading to acquisitive prescription due to long-term, open, and continuous possession as owner.

Issues

• 1. Did the lower court err in dismissing the plaintiffs' complaint for partition based on lack of cause of action?
• 2. Can an invalid donation propter nuptias, due to its form, serve as a legal basis for acquisitive prescription?
• 3. Was acquisitive prescription properly established in favor of the defendant in this case based on the admitted facts and stipulations?

Ruling

• 1. The Supreme Court ruled in favor of the Defendant, affirming the lower court's dismissal. The Court reasoned that while the donation was indeed invalid in form, it provided sufficient basis for the Defendant's claim of adverse possession in the concept of owner. Plaintiffs' own admissions in their pleadings and the stipulation of facts established that the defendant had been in open, continuous, adverse, and public possession for more than the required prescriptive period, thus validly acquiring ownership through acquisitive prescription. The Court concluded the lower court did not err in finding no cause of action for partition.

Doctrines

• 1. Acquisitive Prescription: Ownership of immovable property can be acquired through adverse possession for a period of thirty years. The defendant successfully invoked this doctrine due to his long and continuous possession.
• 2. Donation Propter Nuptias (Formality): Donations of immovable property propter nuptias must be made in a public document to be valid. While the donation was invalid due to lack of public document, it still served as basis for adverse possession.

Key Excerpts

• 1. "While the verbal donation, under which the defendants, and his predecessors in interest have been in possession of the lands in question, is not effective as a transfer of title, yet it is a circumstance which may explain the adverse and exclusive character of the possession."
• 2. "Any person who claims right of ownership over immovable properties and does not invoke that right but instead tolerated others in possession for thirty years is guilty of laches and negligence and he must suffer the consequences of his acts."

Precedents Cited

• 1. Pensader vs. Pensader, 47 Phil., 959: Used to support the principle that an invalid donation can demonstrate the adverse character of possession necessary for prescription.
• 2. Dimaliwat vs. Dimaliwat, 55 Phil., 673-680: Cited as precedent for recognizing invalid donations as a basis for acquisitive prescription in partition cases.

Statutory and Constitutional Provisions

• 1. Article 633 of the old Civil Code.
• 2. Article 1328 of the old Civil Code.