In Ankoanda v. Walker-Smith (1996) 44 Cal.App.4th 610, the Court held that the three-year statute of limitations of section 338(d) barred an action seeking to quiet title brought by an owner of real property against a defendant who was both a cousin and a tenant of the property, and to whom the plaintiff had also given deeds creating a tenancy in common and a joint tenancy. The plaintiff based her quiet title complaint upon a theory of fraud and mistake, but the record clearly indicated that she had known for well over three years that the defendant claimed an ownership interest based on the deeds. The court reversed a trial court decree quieting title in the plaintiff because of the bar of section 338(d). The court held: "The law is clear that the theory of relief underlying an action for quiet title, in this case fraud or mistake, determines which statute of limitations applies. A cause of action subject to section 338, subdivision (d), does not accrue 'until the discovery, by the aggrieved party, of the facts constituting the fraud or mistake.' . . . The record is crystal clear that Ankoanda knew or should have known facts constituting this alleged fraud or mistake in July of 1989. . . . Thus, absent some tolling of the statute of limitations, Ankoanda's complaint was time barred when it was filed on June 28, 1993." ( Id. at p. 615.) In Ankoanda, we were quite explicit in defining the quality of possession required to trigger applicability of the Muktarian v. Barmby (1965) holding: "The 'possession' required to toll the statute of limitations must be 'exclusive and undisputed.' Although Muktarian does not explicitly refer to 'exclusive and undisputed possession,' that type of possession was in fact present there and in the cases relied upon in it." ( Ankoanda, supra,44 Cal.App.4th at p. 616.) The court then went on to note that most of the precedents relied upon by the Court in Muktarian supported our interpretation of its holding. For example, we quoted this passage from Sears v. County of Calaveras (1955) 45 Cal.2d 518, 521, 289 P.2d 425: "'The contention that a statute limiting the time for the commencement of an action to set aside a deed to the state for delinquent taxes does not apply to an owner in exclusive and undisputed possession of the property taxed, is largely based on a rule stated to be that a general statute of limitations does not run against such an owner to remove a cloud upon his title. It may be assumed that such is the general rule. " (Ankoanda, supra, 44 Cal.App.4th at p. 616.) We then observed that other cases relied on by Muktarian, and even later cases citing it, were consistent with the interpretation that only exclusive and undisputed possession by the quiet title plaintiff tolled the running of any statute of limitations. ( Id. at p. 617.) The court concluded that, in view of the fact that the plaintiff in that case was clearly not in exclusive and undisputed possession of the San Francisco house in question, the three-year statute of limitations was applicable and her suit barred by it. ( Id. at p. 618.)