Recoletos v. Crisostomo

Summary

This landmark 1915 case established the rule in Philippine jurisprudence that adverse possession of real property may be proved under a general denial without requiring special pleading. The Supreme Court distinguished between prescription that merely bars remedy (which must be specially pleaded) and adverse possession that transfers title (which may be proved under general denial). The Court extensively analyzed American jurisprudence and procedural law, holding that under the Code of Civil Procedure, adverse possession for the statutory period both extinguishes the original owner's title and vests complete title in the adverse possessor. This dual operation allows adverse possession to be treated as a direct denial of plaintiff's ownership rather than an affirmative defense requiring special pleading. The decision established important precedent for property law and civil procedure in the Philippines.