In Segundina Heluhano Arano v. Delilah L. Pulido, et al., the Supreme Court addressed a dispute over land possession involving an excess area beyond the originally sold property. The Court ruled that the respondents had a better right of possession due to their long-term, open, and continuous possession of the disputed area, even beyond what was stipulated in the initial sale. This decision emphasizes the importance of actual, continuous possession in determining land rights, especially in cases involving unregistered properties.

Land Disputes: How Long-Term Possession Shapes Property Rights

The case revolves around a piece of land originally owned by Rogaciana Roca, who sold a portion of it to Alfredo Pulido in 1965. After Rogaciana’s death, her daughter, Segundina Heluhano Arano, inherited the remaining part of the land and later contested the extent of Alfredo’s property, claiming an excess area of 1,688 square meters. This led to a legal battle to determine who had the superior right of possession over the disputed area.

The initial point of contention involved a prior forcible entry case, which the lower courts used as a basis for res judicata, meaning the issue had already been decided. However, the Court of Appeals (CA) clarified that while the forcible entry case did address possession, it did not fully encompass the issue of ownership, especially concerning the excess area. The Supreme Court (SC) agreed with the CA on this matter, emphasizing that the principle of conclusiveness of judgment only applied to the originally sold 5,000-square-meter portion, as definitively pronounced in the earlier forcible entry case.

Building on this clarification, the Supreme Court focused on determining who had the better right of possession over the 1,688-square-meter excess. The Court highlighted that the respondents (Alfredo Pulido’s heirs) had been in actual possession of the disputed property, including the excess area, since the initial sale in 1965. Segundina, on the other hand, failed to provide sufficient evidence of her prior possession. This distinction is crucial in accion publiciana cases, which are actions to recover the right of possession when dispossession has lasted more than one year, and a claim of forcible entry is no longer applicable.

To further clarify the legal framework, the Court addressed the issue of prescription, which is the acquisition of rights through the passage of time. Since the land in question was unregistered, the Court considered whether Segundina’s claim was barred by the respondents’ long-term possession. The CA applied extraordinary acquisitive prescription in favor of the respondents, noting their open, continuous, and adverse possession of the excess area for over 40 years. This meant that even without a formal title, the respondents had acquired rights to the property through their long-standing occupation.

The Court also considered the nature of the sale between Rogaciana and Alfredo. Article 1542 of the Civil Code provides guidance on sales of real estate made for a lump sum. It states that when property is sold for a lump sum and not by unit of measure, the price does not change regardless of whether the actual area is more or less than what was stated in the contract. The Supreme Court referenced this article, aligning with the CA’s observation that since the property was sold with defined boundaries and for a lump sum, Rogaciana was obligated to deliver the entire area within those boundaries.

Art. 1542. In the sale of real estate, made for a lump sum and not at the rate of a certain sum for a unit of measure or number, there shall be no increase or decrease of the price, although there be a greater or less area or number than that stated in the contract.

However, the Court clarified that their decision was provisional and limited to determining the better right of possession, not ownership. This distinction is significant because it means that while the respondents had a superior claim to possess the land, Segundina could still pursue a separate action to determine ownership. This highlights the difference between possession and ownership in property law, where possession refers to the physical control of the property, while ownership refers to the legal right to the property.

The Court’s reasoning also considered the practical aspects of the situation. The fact that the respondents had occupied more than the initially sold area since 1965, and that Segundina had not taken action until 2005, indicated that the excess area was indeed part of the original agreement. This long-term possession, coupled with Segundina’s inaction, strengthened the respondents’ claim to the disputed property.

Moreover, the Court addressed Segundina’s argument that the excess area was beyond the phrase “more or less” typically used in property descriptions. The Court acknowledged that while there are limits to what can be considered “more or less,” Segundina’s failure to act for an extended period significantly weakened her claim. This highlights the importance of timely action in property disputes, as delays can impact one’s legal rights.

In summary, the Supreme Court’s decision in Segundina Heluhano Arano v. Delilah L. Pulido, et al. emphasizes the critical role of actual, continuous possession in determining land rights. Even in cases where the exact boundaries or areas are unclear, long-term, open, and adverse possession can establish a superior right of possession, particularly in unregistered lands. However, it is equally important to recognize that the determination of possession does not automatically equate to ownership, and parties may still pursue separate actions to resolve ownership issues.

FAQs

What was the main issue in this case?	The central issue was determining who had the better right of possession over a 1,688-square-meter area in excess of the 5,000-square-meter property originally sold. The dispute arose between the seller’s heir and the buyer’s successors.
What is accion publiciana?	Accion publiciana is an action to recover the right of possession of a property when the dispossession has lasted for more than one year, and the summary action of forcible entry or unlawful detainer is no longer available. It seeks to determine who has the better right to possess, independently of title.
What is extraordinary acquisitive prescription?	Extraordinary acquisitive prescription is the acquisition of ownership of a property through uninterrupted adverse possession for a specific period, even without a title or good faith. In this case, it was applied due to the respondents’ long-term possession of the unregistered land.
What does “more or less” mean in property sales?	The phrase “more or less” in property sales acknowledges minor discrepancies between the stated and actual area. However, it does not cover significant excesses, and the specific context of the sale and the parties’ actions are considered in determining its applicability.
How did the prior forcible entry case affect the ruling?	The prior forcible entry case established the respondents’ right to possess the initial 5,000-square-meter property. While the principle of res judicata did not fully apply to the excess area, the established fact of prior possession was still a factor in the court’s decision.
What is the significance of possessing unregistered land?	Possessing unregistered land for an extended period can lead to the acquisition of ownership through prescription. This is because unregistered lands are not covered by the Torrens system, which provides conclusive evidence of ownership, making possession a more critical factor.
What is the difference between possession and ownership?	Possession refers to the actual physical control and enjoyment of a property, while ownership is the legal right to the property. One can possess a property without owning it, and vice versa, though ownership generally implies the right to possess.
Why was the petitioner’s claim ultimately denied?	The petitioner’s claim was denied because she failed to provide sufficient evidence of prior possession over the disputed area. The respondents’ long-term and continuous possession, combined with the circumstances of the initial sale, established their superior right to possess.

This case underscores the importance of documenting property agreements clearly and addressing discrepancies promptly. The ruling highlights the legal consequences of long-term possession, especially in the context of unregistered lands. It also clarifies the distinction between possession and ownership, emphasizing that a determination of possession does not necessarily resolve ownership claims.

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: Segundina Heluhano Arano v. Delilah L. Pulido, G.R. No. 248002, March 15, 2022