Petitioner
Heirs of Marcelina Arzadon-Crisologo
Respondent
Agrifina Rañon
Citation
G.R. No. 171068
Court
Supreme Court
Division
Third Division
Ponente
Chico-Nazario, J.
Decided
September 5, 2007

Summary

This property ownership dispute involved competing claims over an unregistered residential lot in Ilocos Norte. Petitioners claimed succession rights from their predecessors who allegedly purchased the property in 1936, while respondents claimed ownership through acquisitive prescription after possessing it since 1962. The Supreme Court affirmed lower court findings that respondents acquired ownership through extraordinary acquisitive prescription under Article 1137 of the Civil Code, having possessed the property openly, continuously, and notoriously for over 30 years. The Court emphasized that petitioners' 1977 Notice of Adverse Claim did not interrupt the prescriptive period as it failed to constitute judicial summons required under Article 1123. The decision reinforces the principle that the law aids the vigilant, not those who sleep on their rights, and establishes that tax payments coupled with actual possession strongly support ownership claims through prescription.

Intellegal Wiki · Key Holding

Civil interruption of prescription requires a judicial summons (Article 1123); a notice of adverse claim does not interrupt it, and open, continuous, exclusive, and notorious possession for over thirty years gives ownership by extraordinary acquisitive prescription (Article 1137).

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By the Intellegal Editorial Board · September 5, 2007

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