Lorenza Quison v. Higina Salud

Summary

This 1908 Supreme Court case involved a property boundary dispute between heirs of Claro Quison and Higina Salud over land between the estero Nagsaulay and a line of trees. The Court affirmed the lower court's finding that the true boundary was the tree line, not the estero, based on witness testimony of actual occupation by Quison's heirs south of the river. The Court rejected defendant's documentary evidence from an 1887 case as insufficient to overcome evidence of actual possession. Significantly, the Court addressed procedural requirements for married women plaintiffs, allowing amendment to add their husbands as necessary parties since husbands have interests in rents and profits of paraphernal property under the Civil Code. The decision demonstrates early application of liberal amendment rules to serve justice while protecting substantive conjugal property rights. Damages of P900 were awarded for wrongful occupation.