**Case Digest: G.R. No. 171068 (Heirs of Marcelina Arzadon-Crisologo v.

Agrifina Rañon)**

**Facts:**

- Agrifina Rañon filed a Complaint in 1995 against spouses Montemayor, claiming ownership of an
unregistered residential lot.

- Rañon asserted continuous possession since 1962, but in 1986, discovered the property under the
spouses Montemayor's name due to an Affidavit of Ownership.

- Petitioners, heirs of Marcelina Arzadon-Crisologo, intervened, claiming rightful ownership based on

predecessors-in-interest, the Alcantara spouses.

**Issues:**

1. Whether Agrifina Rañon's adverse possession ripened into ownership.

2. Whether the heirs of Marcelina Arzadon-Crisologo have a valid claim based on succession.

**Ruling:**

1. The Municipal Circuit Trial Court (MCTC) declared in 2001 that Rañon's possession was interrupted in
1977 due to an adverse claim, not ripening into ownership. The Regional Trial Court (RTC) reversed in
2002, and the Court of Appeals affirmed in 2005.

2. The MCTC ruled in favor of the heirs in 2001, based on succession and adverse possession. Still, the
RTC reversed in 2002, and the Court of Appeals affirmed in 2005.

**Legal Points:**

- Ordinary acquisitive prescription requires ten years of possession with good faith and just title, while
extraordinary acquisitive prescription demands uninterrupted adverse possession for thirty years
without the need for title or good faith.

- The Court emphasized the judicial character of civil interruption, stating that it's produced by judicial
summons to the possessor. A Notice of Adverse Claim does not substitute for this requirement.

**Conclusion:**
The Court denied the petition, affirming the Court of Appeals' decision. It upheld that Agrifina Rañon
acquired ownership through uninterrupted adverse possession, and the heirs of Marcelina Arzadon-
Crisologo failed to prove their claim based on succession.

*Note: This case digest is a summary and simplification of the provided information and legal analysis.*