Primary Holding

The respondents, Heirs of Agrifina Rañon, validly acquired ownership of the subject property through extraordinary acquisitive prescription because they demonstrated continuous, peaceful, public, notorious, uninterrupted, and adverse possession in the concept of an owner for over thirty years.

Background

Agrifina Rañon filed a complaint against spouses Montemayor to quiet title over a residential lot, claiming ownership based on long and continuous possession since 1962. The Heirs of Arzadon-Crisologo intervened, asserting their rights as successors-in-interest of the original owners and claiming that Rañon's possession was not in good faith and did not ripen into ownership. The spouses Montemayor were later dropped as parties as they had repurchased the property from the Arzadons. The Municipal Circuit Trial Court (MCTC) initially ruled in favor of the Arzadon heirs, but the Regional Trial Court (RTC) reversed this decision, favoring the Rañons through acquisitive prescription. The Court of Appeals affirmed the RTC’s decision.

Facts

• 1. Agrifina Rañon claimed continuous, peaceful, and uninterrupted possession of the unregistered residential lot since 1962, religiously paying taxes.
• 2. Rañon's family built a house on the property and resided there.
• 3. In 1986, the house was destroyed by fire, but the family continued to visit the property and pay taxes.
• 4. In August 1986, Rañon discovered that the spouses Montemayor had obtained a tax declaration in their name based on an Affidavit of Ownership and Possession they executed.
• 5. The Heirs of Arzadon-Crisologo claimed ownership through succession from Timoteo and Modesta Alcantara, who allegedly purchased the property in 1936 and were their predecessors-in-interest.
• 6. The Arzadon heirs asserted that the Rañons' possession was interrupted in 1977 when their predecessor-in-interest filed an adverse claim.
• 7. Respondents presented evidence of continuous possession since 1962, including tax declarations and testimonies of witnesses confirming their long-term occupancy, starting even before 1962.
• 8. Petitioners did not take concrete steps to assert their successional rights until 1977 and did not file a judicial action to interrupt the prescription period.

Arguments of the Petitioners

• 1. They are the rightful owners of the property as heirs of the original owners, Timoteo and Modesta Alcantara.
• 2. The Rañons’ possession was not in good faith and did not ripen into ownership through prescription.
• 3. The adverse claim they filed in 1977 effectively interrupted the prescriptive period.
• 4. Evidence does not support the Rañons' claim of public, notorious, and uninterrupted possession in the concept of an owner since 1962.
• 5. The MCTC correctly found that the respondents did not prove adverse possession for an uninterrupted period of thirty years.

Arguments of the Respondents

• 1. They and their predecessors have been in continuous, peaceful, public, notorious, uninterrupted, and adverse possession of the property as owners since 1962, and even earlier, since 1947.
• 2. Valentin Rañon's affidavit in 1962 expressly repudiated any claim of the petitioners' predecessors.
• 3. They religiously paid real estate taxes, declared the property in their name for taxation, and exercised acts of dominion over the property for over thirty years.
• 4. The filing of the adverse claim in 1977 by the petitioners did not constitute a civil interruption as it was not followed by a judicial summons or action.
• 5. They acquired the property through extraordinary acquisitive prescription under Article 1137 of the Civil Code.

Issues

• 1. Whether the Court of Appeals erred in affirming that the respondents acquired ownership of the subject property through extraordinary acquisitive prescription.
• 2. Whether the respondents' possession was continuous, public, adverse, and in the concept of an owner for the required period.
• 3. Whether the petitioners’ filing of an adverse claim in 1977 effectively interrupted the prescriptive period.

Ruling

• 1. The Supreme Court ruled in the negative regarding the error of the Court of Appeals and affirmed their decision. The Court held that the respondents successfully established extraordinary acquisitive prescription.

Rationale

• 1. The Rañons' possession commenced in 1962 and continued uninterrupted until the filing of the complaint in 1995, exceeding thirty years. Evidence showed possession dating back even further, to 1947.
• 2. The execution of Valentin Rañon's affidavit in 1962 and subsequent actions like tax payments and declarations of ownership constituted a clear repudiation of the petitioners' predecessors' title, making their possession adverse.
• 3. The petitioners' filing of an adverse claim in 1977 did not interrupt the prescription because Article 1123 of the Civil Code requires judicial summons for civil interruption, which was not initiated by the petitioners. A mere notice of adverse claim is insufficient.
• 4. The Court affirmed the factual findings of the RTC and Court of Appeals, which are generally binding, stating that the respondents' possession met all the requisites for extraordinary acquisitive prescription.

Doctrines

• 1. Extraordinary Acquisitive Prescription: Ownership of immovable property can be acquired through uninterrupted adverse possession for thirty years without need of title or good faith, as provided by Article 1137 of the Civil Code.
• 2. Civil Interruption of Prescription: According to Article 1123 of the Civil Code, civil interruption is produced only by judicial summons to the possessor. Extra-judicial demands or notices, such as an adverse claim, are insufficient to interrupt prescription.
• 3. Doctrine of Factual Findings of the Court of Appeals: Findings of fact by the Court of Appeals, especially when they affirm those of the trial court, are generally binding on the Supreme Court, unless specific exceptions apply.
• 4. Vigilantibus sed non dormientibus jura subveniunt: The law aids the vigilant, not those who sleep on their rights. This principle underscores the importance of timely assertion of rights to prevent forfeiture through inaction.

Key Excerpts

• 1. "Civil interruption is produced by judicial summons to the possessor."
• 2. "The law comes to the succor only to aid the vigilant, not those who slumber on their rights."
• 3. "The party who asserts ownership by adverse possession must prove the presence of the essential elements of acquisitive prescription."
• 4. "Tax declarations or realty tax payments of property are not conclusive evidence of ownership, nevertheless, they are good indicia of possession in the concept of owner..."

Precedents Cited

• 1. Ledita Burce Jacob v. Court of Appeals: Cited by the RTC regarding the principle that the law aids the vigilant, not the sleepy, in the context of stale claims and acquisitive prescription.
• 2. Ramos v. Director of Lands: Cited to define actual possession of land, stating it consists of acts of dominion and does not require continuous physical presence on every part of the land.
• 3. Somodio v. Court of Appeals: Further reinforces the definition of actual possession and dominion over property.
• 4. Ferrer v. Bautista: Cited by the Court of Appeals in its Decision dated 10 November 2005, likely regarding civil interruption of prescription.
• 5. Calicdan v. Cendaña; Director of Lands v. Intermediate Appellate Court; Lubos v. Galupo; Aguirre v. Court of Appeals; Republic of the Philippines v. Sandiganbayan; David-Chan v. Court of Appeals; Reyes v. Court of Appeals; Siguan v. Lim; Sta. Maria v. Court of Appeals; Republic of the Philippines v. Court of Appeals; Spouses Reyes v. Court of Appeals: Cited as jurisprudence related to acquisitive prescription, possession, factual findings of the CA, and other relevant legal principles discussed in the case. The specific relevance of each case would require further examination of the full text.

Statutory and Constitutional Provisions

• 1. Article 1137 of the Civil Code: Extraordinary Acquisitive Prescription of immovables (30 years without need of title or good faith).
• 2. Article 1117 of the Civil Code: Acquisitive prescription of dominion and other real rights may be ordinary or extraordinary.
• 3. Article 1134 of the Civil Code: Ordinary Acquisitive Prescription of immovables (10 years with good faith and just title).
• 4. Article 1123 of the Civil Code: Civil Interruption of Prescription is produced by judicial summons to the possessor.
• 5. Article 1124 of the Civil Code: Limitations as to when judicial summons shall not be deemed to have interrupted prescription (void summons, desistment from complaint, absolved possessor).
• 6. Article 1001 of the Civil Code: Succession rights of siblings and spouse when surviving without issue (cited by MCTC, but not central to SC ruling on prescription).