FACTS

On September 15, 1959, petitioners-spouses Hilario Ramirez and Valentina Bonifacio filed an application for registration of a parcel of riceland in Rizal. In their application for registration, they alleged that to the best of their knowledge and belief, there is no mortgage or encumbrance of any kind whatsoever affecting said land and that they had acquired it by purchase from certain Gregoria Pascual during the early part of the American regime but the corresponding contract of sale was lot and no copy or record of the same was available. The Court found, however, that the applicants are not the owners of the land sought to be registered. They were ANTICHRETIC CREDITORS- mere holders placed in possession of the land by its owners as security for loan. The applicants were found guilty of fraudulent misrepresentation and concealment when they declared that no other person had any claim or interest in the said land. ISSUE Can an antichretic creditor acquire land of debtor by prescription? HELD No. The petitioners are not possessors in the concept of owners, but mere HOLDERS placed in possession of land by its owners. Thus, their possession cannot serve as a title for acquiring dominion. The court, from other cases like Trillana v. Manansala, Valencia v. Acala and Barretto v. Barretto, held that the antichretic creditor cannot ordinarily acquire by prescription the land surrendered to hum by the debtor.

Digest courtesy of Vanessa.