This case clarifies how long someone needs to occupy a piece of land to legally claim it, even if they didn’t own it initially. The Supreme Court ruled that Silverio Cendaña rightfully owned the land in question through extraordinary acquisitive prescription, because he openly and continuously possessed the property for over 45 years, despite the initial donation being invalid. This means that long-term, open possession can lead to ownership, offering a path for those who occupy land for extended periods to gain legal title.

The Land, the Donation, and the Decades-Long Dispute

The legal battle began over a 760-square-meter piece of unregistered land in Mangaldan, Pangasinan, once owned by Sixto Calicdan. After Sixto’s death, his wife, Fermina, donated the land to Silverio Cendaña in 1947. Silverio then took possession, building a house and living there for decades. In 1992, Soledad Calicdan, Sixto’s daughter, challenged the donation, claiming it was invalid and that Silverio was merely tolerated on the property. This prompted a legal showdown that ultimately reached the Supreme Court, centering on the validity of the donation and whether Silverio had acquired ownership through long-term possession.

The trial court initially sided with Soledad, ordering Silverio to vacate the land. However, the Court of Appeals reversed this decision, declaring the donation valid and stating that Soledad had lost ownership through prescription. Prescription, in legal terms, is the acquisition of ownership through the continuous passage of time. Dissatisfied, Soledad elevated the case to the Supreme Court, questioning both the validity of the donation and whether prescription applied. At the heart of this case lies the question: Can long-term possession, even without a valid title, transform someone into the legal owner of a property?

The Supreme Court addressed two key issues: the validity of the donation and whether Soledad lost ownership of the land through prescription. Initially, the Court examined whether Fermina had the right to donate the land to Silverio. Based on the evidence, the Court found the donation invalid. Silverio himself admitted that he had no personal knowledge of how Sixto Calicdan acquired the property. This lack of evidence undermined the claim that Fermina had the authority to donate the land.

The Court emphasized that witnesses can only testify about facts they know personally. Because Silverio’s testimony about the land’s history was based on hearsay, it could not be considered as valid evidence of the donation.

Under Rule 130, Section 36 of the Rules of Court, a witness can testify only to those facts which he knows of his own personal knowledge, i.e., which are derived from his own perception; otherwise, such testimony would be hearsay.

Consequently, the Supreme Court agreed with the trial court’s initial assessment that the donation was not valid.

Despite the invalid donation, the Supreme Court ultimately ruled in favor of Silverio, focusing on the concept of **extraordinary acquisitive prescription**. This legal principle allows someone to acquire ownership of property through uninterrupted adverse possession for thirty years, regardless of whether they have a valid title or acted in good faith. This contrasts with **ordinary acquisitive prescription**, which requires possession in good faith and with a just title for ten years. Here, the key difference lies in the length of possession and the requirement of good faith.

The Court found that Silverio met the requirements for extraordinary acquisitive prescription. He had been in possession of the land for 45 years, starting from the time of the donation in 1947 until the filing of the case in 1992. This possession was deemed public, adverse, and in the concept of an owner. Silverio had fenced the land, built a house, cultivated the land, and paid the property taxes.

Although tax declarations or realty tax payment of property are not conclusive evidence of ownership, nevertheless, they are good indicia of possession in the concept of owner, for no one in his right mind would be paying taxes for a property that is not in his actual or constructive possession.

This action demonstrated his intent to possess the property as his own.

Even though the deed of donation was invalid, the Court noted that it could still be used to demonstrate the exclusive and adverse nature of Silverio’s possession. In other words, even an invalid document can provide evidence of a person’s intention to possess the land as the owner. The Supreme Court thus affirmed the Court of Appeals’ decision to dismiss the case. Silverio Cendaña was declared the rightful owner of the property, not because of the donation, but because of his long-term, open, and adverse possession.

This case serves as a reminder that long-term possession can indeed lead to ownership, even without a valid title. The decision highlights the importance of protecting one’s property rights and taking timely legal action when necessary. It also underscores the significance of understanding the legal concept of acquisitive prescription, which can have a profound impact on property ownership.

FAQs

What was the key issue in this case?	The key issue was whether Silverio Cendaña had rightfully acquired ownership of the land through either a valid donation or through acquisitive prescription, given his long-term possession.
Why was the donation declared invalid?	The donation was declared invalid because there was no concrete evidence that Fermina, the donor, had the right to donate the property. Silverio’s testimony about the land’s history was based on hearsay.
What is acquisitive prescription?	Acquisitive prescription is a way to acquire ownership of property through the continuous passage of time and possession, as defined by law. There are two types: ordinary and extraordinary acquisitive prescription.
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 the need for title or good faith.
How did Silverio Cendaña acquire the land, according to the Supreme Court?	The Supreme Court ruled that Silverio acquired the land through extraordinary acquisitive prescription because he had openly and continuously possessed the land for over 45 years, far exceeding the required 30 years.
What evidence supported Silverio’s claim of ownership through prescription?	Evidence supporting Silverio’s claim included the fact that he fenced the land, built a house on it, cultivated the land, paid property taxes, and possessed it openly and continuously for decades.
Can a void deed be used as evidence in a claim of acquisitive prescription?	Yes, even if a deed is void, it can still be used as evidence to show the adverse and exclusive nature of the possessor’s claim. It helps demonstrate intent to own the property.
What does this case teach about property rights?	This case teaches that long-term possession of property can lead to ownership, even without a valid title, emphasizing the importance of safeguarding one’s property rights and acting promptly to address potential claims.

In conclusion, the Calicdan v. Cendaña case illustrates the legal concept of extraordinary acquisitive prescription and how it can impact property ownership. While the initial donation was deemed invalid, Silverio Cendaña’s decades-long, open possession of the land ultimately led to him being recognized as the rightful owner. This case reinforces the importance of understanding property laws and acting decisively to protect one’s rights.

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: Soledad Calicdan v. Silverio Cendaña, G.R. No. 155080, February 05, 2004