Miguel Pascual v. Macario Angeles

Summary

Miguel Pascual sought registration of inherited land in Navotas comprising four parcels totaling over 53,000 square meters. Two tenants, Marcelo Joingco and Macario Angeles, opposed claiming ownership of portions they occupied. The Court of Land Registration granted registration, dismissing both oppositions. On appeal, the Supreme Court affirmed, finding both oppositors were mere tenants under lease contracts who could not claim ownership. Joingco had signed a 1886 lease contract, while Angeles had been declared a tenant in previous ejectment proceedings. The Court held that tenants possessing by permission cannot establish ownership under Civil Code Article 1942. Pascual's inheritance-based ownership was fully proven through documentary evidence. The decision established important precedent that tenant possession cannot ripen into ownership when based on lease agreements with the true owner.