PROPERTY CONCEPTS AND KINDS

ALANO v. MAGUD-LOGMAO
G.R. No. 175540, 7 April 2014

The Supreme Court ruled that the doctor employed reasonable means to disseminate
notifications intended to reach the relatives of the deceased. Though the notices did not
properly state the name or identity of the deceased, the doctors are not at fault. The hospital
could not have obtained the patient’s name because he was already unconscious upon arrival
at the hospital.

DREAM VILLAGE v. BASES CONVERSION DEVELOPMENT AUTHORITY

G.R. No. 192896, 24 July 2013

Notwithstanding possession in the concept of owner for 30 years, acquisitive

prescription did not set in. Even though the law provided that the lands are now alienable and
disposable, the Civil Code provides that it must be accompanied by an express governmental
manifestation that the property no longer retained for public service or the development of
national wealth to be considered patrimonial and subject to acquisitive prescription. Hence,
Fort Bonifacio is reserved for public service or development of national wealth not subject to
acquisitive prescription.

LAUREL v. ABROGAR
G.R. No. 155076, 13 January 2009

The only requirement for a personal property to be the object of theft under the Penal
Code is that it be capable of appropriation. It need not be capable of “asportation” or capable
of being “carried away”. To appropriate means to deprive the lawful owner of the thing.
While it may be conceded that “international long distance calls” take the form of electrical
energy, it cannot be considered as personal properties of PLDT since the latter could not have
acquired ownership over such calls. PLDT merely encodes, augments, enhances, decodes and
transmits said calls using its complex communications infrastructure and facilities. PLDT not
being the owner of said telephone calls, it could not validly claim that these were taken
without its consent. It is the use of these communications facilities without the consent of
PLDT that constitutes the crime of theft, which is the unlawful taking of the telephone
services and business.