Tranquilina Alcala v. Pedro Hernandez

Summary

This 1915 Supreme Court case involved a land dispute where Tranquilina Alcala sold the Nalbo land to Pedro Hernandez and Potenciana Pacleb in 1909 for P700, then sued to recover the value of fruits collected during the defendants' fifteen-year possession prior to the sale. The Court dismissed the case, finding that Alcala had clearly waived all rights to the property in the sale instruments and that the defendants were good faith possessors since 1894. Applying Civil Code Article 451, the Court ruled that fruits collected during good faith possession belong to the possessor. The decision established that clear contractual waivers and good faith possession bar subsequent claims for fruits collected during the possession period.