In the case of Lina Abalon Lubos v. Marites Galupo, the Supreme Court affirmed that respondents are the rightful owners of a parcel of land. The court found that petitioner Lubos failed to prove acquisition of the land through acquisitive prescription due to lack of good faith and just title. This ruling underscores the importance of demonstrating rightful ownership and continuous, adverse possession when claiming land rights based on prescription.

Land Battles: Did Possession Translate to Ownership?

The central question in this case revolves around the concept of acquisitive prescription, a legal principle that allows a person to acquire ownership of property through continuous possession over a certain period. There are two kinds of acquisitive prescription under the Civil Code: ordinary and extraordinary. The main difference lies in the length of the required possession period and the presence of good faith and just title.

The respondents, the Galupo family, claimed ownership of the land based on a 1928 Escritura de Compra y Venta (Deed of Sale) between Victoriana Dulay and Juan Galupo. Petitioner Lubos, on the other hand, asserted that the land was originally owned by Victoriana Dulay, her great-grandmother, who purportedly sold it to her father, Juan Abalon. She further contended that her father possessed the property for over thirty years before selling it to her. The trial court sided with the Galupos, a decision affirmed by the Court of Appeals. The Supreme Court was tasked to decide which party had a better right to the land.

The Court delved into the requirements for acquisitive prescription, emphasizing that possession must be in the concept of an owner, public, peaceful, and uninterrupted. Articles 1134 and 1137 of the Civil Code provide for the periods of possession:

“Art. 1134. Ownership and other real rights over immovable property are acquired by ordinary prescription through possession of ten years.”

“Art. 1137. Ownership and other real rights over immovables also prescribe through uninterrupted adverse possession thereof for thirty years, without need of title or of good faith.”

The Court found that petitioner Lubos did not have just title because the alleged contract between her and her father, Juan Abalon, was deemed fictitious. For the purposes of prescription, there is just title when the adverse claimant came into possession of the property through one of the modes recognized by law for the acquisition of ownership or other real rights, but the grantor was not the owner or could not transmit any right. This is further connected to good faith, which the Court said was also absent in Lubos’ case. Good faith consists in the reasonable belief that the person from whom the possessor received the thing was its owner but could not transmit the ownership thereof. Lubos failed to present sufficient documentary evidence to prove the transfer of the land from Victoriana Dulay to her father.

Even if Lubos and her father possessed the property in the concept of owner, the Court pointed out that the required period for extraordinary acquisitive prescription (thirty years) had not been met when the respondents filed the case in 1991. The testimonies of the tenants indicated possession by Juan Abalon from 1963, which is short of the thirty-year requirement. In contrast, the Galupos presented the Escritura de Compra y Venta, an ancient document, which the court deemed admissible even without translation because there was no objection made by the other party.

Ultimately, the Supreme Court upheld the lower courts’ rulings, finding that the Galupos had a superior claim to the land. The Court found no documentary evidence showing that the transfer occurred. Therefore, Lubos did not meet the legal requirements for acquisitive prescription.

FAQs

What was the key issue in this case?	The central issue was whether Lina Abalon Lubos acquired ownership of the land through acquisitive prescription, which requires possession in good faith and with just title over a certain period.
What is acquisitive prescription?	Acquisitive prescription is a legal principle that allows a person to acquire ownership of property by possessing it continuously, publicly, and adversely for a period of time prescribed by law.
What is the difference between ordinary and extraordinary acquisitive prescription?	Ordinary acquisitive prescription requires possession in good faith and with just title for ten years, while extraordinary acquisitive prescription requires uninterrupted adverse possession for thirty years, without need of title or of good faith.
What is considered a “just title” in relation to acquisitive prescription?	A “just title” exists when the adverse claimant came into possession of the property through one of the modes recognized by law for acquiring ownership, but the grantor was not the owner or could not transmit any right.
What is the significance of the Escritura de Compra y Venta in this case?	The Escritura de Compra y Venta (Deed of Sale) was crucial as it served as evidence that Victoriana Dulay sold the land to Juan Galupo, establishing the Galupo family’s claim to the property.
Why was the Escritura de Compra y Venta admitted as evidence even though it was in Spanish?	The court admitted the Escritura de Compra y Venta as an ancient document and because its admission was not objected to by the adverse party at the proper time.
What evidence did Lubos present to support her claim of ownership?	Lubos primarily relied on the testimonies of tenants who worked on the land, suggesting that her father, Juan Abalon, had possessed the property for a long time.
Why did the court reject Lubos’s claim of acquisitive prescription?	The court rejected Lubos’s claim because she failed to prove that she had acquired just title and good faith, and the required period of uninterrupted adverse possession had not been met.
What happens to the sale of the portion of the land Lubos made to the spouses Poldo?	The Court nullified the sale executed by Lubos in favor of the Spouses Poldo, because she did not have the title to the land, making the sale void.

This case serves as a reminder of the stringent requirements for acquiring land through acquisitive prescription. Claimants must demonstrate not only continuous possession but also the presence of good faith and just title, supported by concrete evidence. Failure to meet these requirements can result in the loss of property rights, as seen in this instance.

For inquiries regarding the application of this ruling to specific circumstances, please contact ASG Law through contact or via email at frontdesk@asglawpartners.com.

Disclaimer: This analysis is provided for informational purposes only and does not constitute legal advice. For specific legal guidance tailored to your situation, please consult with a qualified attorney.
Source: LINA ABALON LUBOS VS. MARITES GALUPO, G.R. No. 139136, January 16, 2002