Where it appears that there has been an actual continued occupation of land, under a claim of title, exclusive of any other right, but not founded upon a written instrument, judgment, or decree, the land so actually occupied, and no other, is deemed to have been held adversely.

SOURCE: CP § 324.

COMMENT: Court cases have long established that adverse possession cannot be made to obtain title in land owned by the government of Guam. See In re application of Andersen Iglesias, 1 Guam R. 129, 142.