Department of Education v · G.R. 192268

Petitioner: Department of Education
Respondent: Delfina C. Casibang
Citation: G.R. No. 192268
Court: Supreme Court
Division: Third Division
Ponente: Peralta, J.
Decided: January 27, 2016

Summary

The Supreme Court resolved a property dispute between the Department of Education and the heirs of Juan Cepeda over a 7,532 square meter lot used as a school site since 1965. The respondents, as registered owners under OCT No. O-627, sought recovery of possession after tolerating the school's use for decades. DepEd claimed ownership through an alleged purchase by civic-minded residents but failed to present supporting evidence. The Court ruled that DepEd's possession was by mere tolerance, not adverse, and therefore could not ripen into ownership through laches. Applying Civil Code Article 448, the Court recognized DepEd as a builder in good faith and remanded the case to determine property value for appropriate compensation - either payment of land value or reasonable rent depending on the comparative values of land versus improvements.

Statutes applied

Civil Code, Art. 448

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By the Intellegal Editorial Board · January 27, 2016

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