Government of the Phil. vs. Abalos, et al.

Adverse possession beginning during the life of an ancestor is effective against his infant heirs, and the statutory saving in favor of a minor applies only when the right of action accrues during the minor’s lifetime. Additionally, a bona fide purchaser for value from a co-owner who holds apparent exclusive title acquires valid title free from the equity of the other co-owners who permitted the appearance of sole ownership.

Basilio Reguyal died around 1889, allegedly leaving six children and a large tract of land in Umingan, Pangasinan. Adriano Reguyal, one of the sons, took exclusive possession of the property from about 1890. In 1894 he obtained and registered a possessory information covering the entire tract in his own name. In 1909 he sold the property to Domingo Belisario, who subdivided it and sold parcels to over seventy individuals. The heirs of Basilio Reguyal other than Adriano made no open assertion of their claimed rights until 1920, when Paulina Casimina and others filed an action for reivindicacion against the occupants.

• Nature of the Dispute: The consolidated appeals involved two rival claims to eleven lots in Umingan, Pangasinan, forming part of a larger mass of nearly 300 hectares. The appellees were the successors in interest of Adriano Reguyal, son of Basilio Reguyal. The appellants were other descendants of Basilio Reguyal. The core question was whether the land had belonged exclusively to Adriano Reguyal or to him and his siblings in common.

• Appellees’ Chain of Title: Adriano Reguyal held peaceful, exclusive possession from about 1890. In 1894 he obtained and registered a possessory information covering the entire property in his name alone, in due form of law. In 1909 he sold the property for valuable consideration to Domingo Belisario, who took possession immediately. Belisario later sold the land in small parcels to the appellees, numbering over seventy. The evidence showed that Adriano Reguyal enjoyed the produce to the exclusion of all others, and from 1909 onward, Belisario and his successors did the same without disturbance, except for an action for reivindicacion filed in 1920 by Paulina Casimina and others.

• Appellants’ Claim: Basilio Reguyal died around 1889, leaving six children who allegedly inherited the land as common property. The land was never partitioned. The appellants claimed a five-sixths undivided interest. They asserted that the possessory information was taken in Adriano’s name merely because he was the eldest son and it was inconvenient for the others to attend the proceeding. Allegedly, the heirs agreed that the issuance of the information in Adriano’s name would not prejudice their rights.

• Minority of Paulina Casimina: One appellant, Paulina Casimina, was born in 1900 and attained majority in 1921. The appellants invoked her minority to avoid the effects of adverse possession.

• Ownership: Whether the land in controversy belonged exclusively to Adriano Reguyal or to the six heirs of Basilio Reguyal in common.

• Prescription and Minority: Whether the long-continued adverse possession extinguished the appellants’ claims, and whether the minority of Paulina Casimina suspended the running of prescription.

• Innocent Purchaser Doctrine: Whether Domingo Belisario and the appellees, as subsequent purchasers, acquired valid title as innocent purchasers for value free from the appellants’ equitable claims.

• Ownership: The correctness of the assumption that the land pertained to Basilio Reguyal and descended to all his children was open to grave question, resting primarily on the testimony of one appellant. Regardless, the decision did not turn on this factual dispute because other legal grounds were dispositive.

• Prescription and Minority: The adverse possession of Adriano Reguyal began around 1890, before Paulina Casimina’s birth in 1900. The statutory saving in favor of a minor is effective only when the right of action originates during the minor’s life. Where the statute of limitations begins to run against a parent before the child is born, no saving operates in favor of the child. The protection of the statute extends solely to those against whom adverse possession is first asserted and who are under disability at that time. Because prescription commenced during the life of the ancestor, it was effective against the infant heir. By the time the claim was filed, the title of the appellees was already perfect by prescription.

• Innocent Purchaser Doctrine: When the appellants or their ancestors consented to the possessory information being taken exclusively in Adriano Reguyal’s name, he became in effect a trustee for the others, assuming co-ownership existed. Adriano thereby acquired a power of disposition to convey the possessory right to any bona fide purchaser. The appellants’ right was reduced to a mere equity, which is ineffective against Domingo Belisario, an innocent purchaser for value without notice, and those who purchased under him. The same rule applies when a possessory right ripens into title by adverse possession.

• Prescription Against Infant Heirs: A statutory saving in favor of a minor applies only when the right of action accrues during the minor’s lifetime. If adverse possession commences during the life of the ancestor, it will be effective against his infant heirs. The protection is reserved for those against whom adverse possession is first asserted and who may at that time be under a disability. (Citing Armstrong v. Wilcox, Jackson v. Moore, Scallon v. Manhattan R. Co., and Garner v. Wingrove.)

• Equity of Co-Owners Against Innocent Purchasers: Where co-owners permit one of their number to take title in his own name, thereby clothing him with apparent exclusive ownership, any innocent purchaser for value from him who acquires without notice of the rights of the other co-owners obtains valid title free from their equity. This principle extends to possessory rights that ripen into title by adverse possession.

• "Before the statutory saving in favor of a minor can be effective, it must appear that the right of action originated in the life of such minor. In other words, if the statute of limitations once begins to run against a parent, before a child is born, there is no saving in favor of the child." — This passage articulates the rule on prescription against infant heirs and forms the ratio decidendi on the minority issue.

• "When the appellants or their ancestors consented for the possessory information to be taken exclusively in the name of Adriano Reguyal, the latter became a trustee in effect for the others... and Adriano necessarily acquired a power of disposition adequate to convey the possessory right to any bona fide purchaser from him. The right of the appellants was thereby reduced to a mere equity, which is ineffective against Domingo Belisario and purchasers under him." — This captures the alternative equitable ground for denying the appellants’ claim.

• Armstrong v. Wilcox, 57 Fla. 30; 131 A.S.R. 1080 — Cited as authority for the rule that adverse possession beginning during the life of the ancestor is effective against infant heirs.

• Jackson v. Moore, 13 Johns. (N.Y.) 513; 7 Am. Dec. 398 — Followed for the principle that the statutory saving in favor of a minor requires the right of action to have accrued during the minor’s life.

• Scallon v. Manhattan R. Co., 185 N.Y. 359; 7 Ann. Cas. 168 — Relied upon for the same rule on prescription and minority.

• Garner v. Wingrove [1905] 2 Ch. 233; 3 Ann. Cas. 837; 3 British R. Cas. 737 — English authority cited in support of the prescription rule against infant heirs.

• Statutory saving in favor of minors (Prescription): No specific code article was cited; the decision refers generally to the statutory exception for minors under the law on prescription of actions. The rule was applied to mean that the exception is available only when the cause of action accrues during the minority, not when prescription began before the minor’s birth.

• Possessory information (Maura Law or prior land registration regime): The 1894 possessory information registered under the Spanish Mortgage Law was recognized as creating an appearance of exclusive ownership upon which third parties could rely.

Avanceña, C.J., Johnson, Malcolm, Villamor, Ostrand, Romualdez, Villa-Real, and Imperial, JJ., concurred.