What is the test for presumption of ownership of property when a third party has possession of the property without explanation?

It has been held (Rawley v. Brown, 71 N.Y. 85, 89) that "Possession of property alone and without explanation, is evidence of ownership; but is the lowest species of evidence. It is merely presumptive, and liable to be overcome by any evidence showing the character of the possession, and that it is not necessarily as owner. If the custody and possession is shown to be equally consistent with an outstanding ownership in a third person, as with a title in the one having the possession, no presumption of ownership arises solely from such possession." (And see Matter of Duffy, 127 App. Div. 74, 75.)