Invalid permanent lease, unregistered deeds, and adverse possession: long open tenancy barred the landlord's ejectment claim.

The Collector had no effective authority to create a binding permanent tenancy of a minor's lands, and the later lease was not ratified because there was no proved knowledge and adoption by the plaintiff after majority. The earlier unregistered leases could not affect immovable property or be used as evidence of title, though they could explain the nature of possession; the later registered lease was also ineffective as a binding grant because the Collector was functus officio. Possession under the asserted permanent tenancy, however, was openly adverse and continued beyond the statutory period, so the plaintiff's suit for ejectment was barred by limitation.

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Issues: (i) Whether the Collector had authority to grant or later ratify a permanent lease of the minor's lands and whether the plaintiff ratified the later consolidated lease; (ii) Whether the earlier unregistered leases and the later registered lease could be relied upon in evidence; (iii) Whether the defendant's possession under the asserted permanent tenancy had become adverse so as to bar the plaintiff's suit by limitation and, if not, whether the plaintiff could eject without notice.

Issue (i): Whether the Collector had authority to grant or later ratify a permanent lease of the minor's lands and whether the plaintiff ratified the later consolidated lease.

Analysis: The governing power of the Government and the Collector was confined to management of the estate and did not extend to an unlimited alienation or a permanent demise without necessity or benefit. The later governmental endorsement did not amount to express approval or effective ratification, especially as it post-dated the cessation of the Government's guardianship and was not shown to have been made with full knowledge of the earlier transactions. The later lease executed by the Collector after the plaintiff attained majority was not binding as an act of administration, and on the facts the plaintiff did not have the requisite knowledge and adoption to ratify it.

Conclusion: The Collector had no effective authority to create a binding permanent tenancy, and the plaintiff did not ratify the later lease.

Issue (ii): Whether the earlier unregistered leases and the later registered lease could be relied upon in evidence.

Analysis: The earlier documents, though requiring registration, were unregistered and therefore could not operate to affect immovable property or be received as evidence of the transaction affecting such property. The later registered document was also ineffective as a binding grant because it was executed after the Collector had become functus officio. Nevertheless, the earlier documents could be looked at not as operative instruments but as explanatory of the nature and terms of the possession asserted by the defendant.

Conclusion: The unregistered earlier leases were not admissible to affect title, and the later lease was not valid as a binding grant.

Issue (iii): Whether the defendant's possession under the asserted permanent tenancy had become adverse so as to bar the plaintiff's suit by limitation and, if not, whether the plaintiff could eject without notice.

Analysis: Possession under an invalid lease may become adverse where the occupant openly asserts and enjoys the benefits of a title inconsistent with the landlord's title, and adverse possession may exist even as to a limited interest. The defendant from the outset openly claimed a permanent tenancy, acted upon it, and enjoyed its benefits with the knowledge of the plaintiff's representative. That adverse possession continued for more than the statutory period after the plaintiff attained majority. In those circumstances, the plaintiff's claim was barred by limitation. The claim for ejectment without notice could not survive once limitation had run.

Conclusion: The defendant acquired a protective title by adverse possession as permanent tenant, and the plaintiff's suit was time-barred.

Final Conclusion: The plaintiff's challenge to the permanent tenancy failed because the grant was unauthorized, but the defendant's long, open, and notorious assertion of that tenure matured into a barred claim against ejectment by limitation.

Ratio Decidendi: A person in possession under an invalid lease may acquire title by adverse possession to the limited interest openly asserted, and where the landlord or his representative knowingly permits such assertion to continue for the statutory period, the owner's right to recover possession is barred by limitation even though the underlying lease is not operative.

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