Adelaida Tuazon v. Lydia Tuazon

Summary

This Supreme Court case involves a dispute over possessory rights to public land between family members surnamed Tuazon. Petitioners filed what they claimed was an accion reivindicatoria to recover possession of Lot No. 165 from respondents who had been occupying the property since 1967. The RTC initially ruled in favor of petitioners based on previous court decisions establishing their possessory rights. However, the Court of Appeals and Supreme Court correctly characterized the action as accion publiciana since the property is public land and petitioners only hold possessory rights, not ownership. The Supreme Court applied the 10-year prescriptive period for real right of possession under Article 555 of the Civil Code, counting from respondents' adverse occupation since 1967. The Court rejected arguments that prescription was interrupted by intervening litigation, finding that prior cases involved different causes of action. The petition was denied, affirming that petitioners' possessory rights had prescribed.