Primary Holding

The Supreme Court upheld the lower court's judgment, ruling that the plaintiffs' action for partition was barred by prescription because the defendants and their predecessors had been in continuous, adverse possession of the coconut land for over thirty years, under claim of ownership.

Background

The case centers on a claim of inheritance versus a claim of ownership through donation and adverse possession. The plaintiffs, nephews of the deceased Canuto Pensader, sought to partition land they considered common inheritance. The defendants, niece and grand-nephew of Canuto, asserted exclusive rights based on donations made by Canuto and decades of uninterrupted possession. The legal context is property rights, inheritance laws, donation, and the principle of prescription through adverse possession.

Facts

• 1. Canuto Pensader acquired the disputed coconut land from Eulalio Punio.
• 2. Canuto had nephews (plaintiffs) and a niece, Alejandra Pensader (defendant).
• 3. Canuto lived with Maria Revelar without marriage.
• 4. In 1892, Canuto donated half of the land to Maria Revelar and half to Alejandra Pensader.
• 5. Canuto died in 1892.
• 6. Maria Revelar and Alejandra Pensader (with her husband Vicente Revelar) took possession and cultivated the land after Canuto's death.
• 7. After Vicente Revelar's death, his heirs and Alejandra PensaderExtrajudicially partitioned the land, allotting it to Silverio P. Revelar (defendant, Alejandra's son).
• 8. Maria Revelar waived her share of the land in favor of Silverio P. Revelar.
• 9. Silverio P. Revelar and his predecessors (parents and aunt) possessed the land for over thirty years, continuously, publicly, peacefully, and under claim of ownership.
• 10. Plaintiffs made an extrajudicial demand for partition in 1905 but did not succeed.

Arguments of the Petitioners

• 1. The disputed land is an undivided inheritance among the plaintiffs and defendants.
• 2. The lower court erred in finding that the parties held the land in common possession.
• 3. The lower court erred in finding that the possession of Silverio P. Revelar and his predecessors was adverse and lasted for more than thirty years.
• 4. The lower court erred in holding that the plaintiffs' action had prescribed.
• 5. The lower court erroneously found that Canuto Pensader transferred title to Fr. Pablo Pajarillo (though this point was not significantly discussed in the ruling).
• 6. The lower court erred in not admitting parol evidence regarding admissions by Alejandra Pensader and Vicente Revelar about Alejandra's title.

Arguments of the Respondents

• 1. The defendants asserted ownership based on the donation from Canuto Pensader to Alejandra Pensader and Maria Revelar.
• 2. The possession of Alejandra Pensader, Maria Revelar, and Silverio P. Revelar was adverse to the plaintiffs, continuous, public, peaceful, and under claim of ownership for over thirty years.
• 3. Due to this adverse possession for more than thirty years, the plaintiffs' action for partition had prescribed.

Issues

• 1. Was the lower court correct in concluding that the appellants and appellees did not possess the land in common?
• 2. Was the lower court correct in determining that Silverio P. Revelar and his predecessors' possession for over thirty years was adverse to the plaintiffs?
• 3. Did the lower court correctly decide that the plaintiffs’ action for partition had prescribed due to adverse possession?
• 4. Was the lower court's finding regarding the alleged transfer of title to Fr. Pablo Pajarillo erroneous? (Though the court ruling did not significantly address this point).
• 5. Was the lower court’s decision to disallow parol evidence regarding title admissions by Alejandra Pensader and Vicente Revelar erroneous? (Implicitly, the court found other evidence sufficient, rendering this point less relevant to the final ruling).

Ruling

• 1. The Supreme Court found no merit in the errors assigned by the appellants.
• 2. The Court determined that the evidence sufficiently demonstrated the adverse nature of the possession exercised by Silverio P. Revelar and his predecessors in interest, originating from the donation and maintained exclusively.
• 3. The Court emphasized that the continuous, public, peaceful, and adverse possession for over thirty years was sufficient to justify the lower court's ruling that the action for partition had prescribed.
• 4. Consequently, the Supreme Court affirmed the judgment of the lower court, with costs against the appellants.

Doctrines

• 1. Doctrine of Adverse Possession: This doctrine states that a person can acquire ownership of real property by openly, notoriously, exclusively, continuously, and hostilely possessing it for the statutory period (in this case, exceeding thirty years). The court applied this doctrine, finding that the defendants’ possession met all criteria, thus leading to the prescription of the plaintiffs’ action.
• 2. Doctrine of Prescription: This legal principle refers to the extinction of a right by the lapse of time. In this case, the plaintiffs' right to partition the property was lost due to the prescriptive period having been completed by the defendants' adverse possession.