Marcelino Kiamco v. The Honorable Court of Appeals

Summary

This case involves a property ownership dispute resolved through acquisitive prescription principles. Faustino Maningo sold property to Villamor spouses via pacto de retro in 1948, then his father-in-law Jose Deguilmo purchased it from the Villamors in 1950. After Deguilmo possessed the property continuously for over 20 years, Faustino returned in 1973 and sold the same property to petitioner Kiamco. The Supreme Court affirmed that Deguilmo acquired ownership through acquisitive prescription under the Code of Civil Procedure, which required only 10 years of adverse possession regardless of good or bad faith. Since Deguilmo's possession began in 1950 (before the New Civil Code's effectivity), the transitional rule in Article 1116 applied the shorter prescriptive period. The case demonstrates the application of transitional provisions in prescription laws and the doctrine of acquisitive prescription in property disputes.