Title
Alfonso vs. Ferdez
Case
G.R. No. L-38773
Decision Date
Nov 15, 1974
Land dispute resolved via compromise: relocation survey to determine if petitioners' land is within respondents' T.C.T. 14807; admissions disregarded.
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Case Digest (G.R. No. L-38773)

Facts:

    Parties and Nature of the Dispute

    • Petitioners: Miguel Alfonso, Gomercindo Bolante, Carlos Batungbacal, Gregorio Pilorin, Alberto De Guzman, Jacobo Isip, Alfredo Kilakil, Rodito Morabe, Alfredo Panugao, Bayani Ramirez, Agustin Del Rosario, and Ramon De Vera, Jr.
    • Respondents: Hon. Judge Bernardo P. Fernandez (acting through the Court of First Instance of Zambales, Branch III, Olongapo City) and private respondents including Raymundo Dela Paz, Placido De La Paz, Jose Dela Paz, Jr., Iloina Dela Paz, Augusto Dela Paz, Norita Dela Paz, Leonora Dela Paz, and Victoria Dela Paz.
    • The dispute centers on whether the land occupied by the petitioners is included in Transfer Certificate of Title (T.C.T.) No. T-14807 held by the private respondents.

    Procedural History and Pre-Trial Developments

    • During the hearing on October 11, 1974, the Court noted the ambivalence in the admission made by Atty. Jose Sarte (former counsel of the petitioners) during the pre-trial phase.
    • The ambivalent admission raised questions regarding its impact and relevance; however, the parties agreed that this was not the core issue.
    • The sole issue was determined to be the proper inclusion of the land within T.C.T. No. T-14807.

    Compromise Agreement (Stipulation of Facts)

    • The parties submitted a written compromise agreement, inaccurately referred to as the Stipulation of Facts, which was approved by the Court.
    • Key Provisions of the Compromise Agreement:
    • The parties agreed to proceed with the trial in the lower court irrespective of the ambivalent pre-trial admission of Atty. Jose Sarte.
    • A relocation survey was mandated on the land covered by T.C.T. No. T-14807 to definitively determine its boundaries and correct inclusion.
    • Financial Arrangements for the Relocation Survey:
    • The cost of the relocation survey would be shared equally by both parties—one-half borne by the defendants and the other half by the plaintiffs.
    • The winning party in the eventual determination would recover the incurred survey expenses from the losing party as part of the costs.
    • Consent and Binding Effect:
    • All parties involved in Civil Case No. 1133-0 of the Court of First Instance of Zambales, Branch III, except for the nonrepresented defendant Antonio Coronel, agreed to abide by the outcome of the relocation survey.
    • The stipulation was submitted and agreed upon during the Supreme Court hearing, reflecting a mutual resolution mechanism for the pending dispute.

    Court’s Administrative Order

    • The Supreme Court approved the stipulated compromise agreement.
    • The order directed all parties, including the respondent judge or his representative, to abide by and enforce the terms of the compromise.
    • The decision explicitly stated that no costs would be imposed on either party as a result of this order.

Issue:

    Core Contention

    • Whether the land occupied by the petitioners falls within the scope of Transfer Certificate of Title (T.C.T.) No. T-14807 held by the private respondents.

    Subsidiary Consideration

    • The impact, if any, of the ambivalent admission made by Atty. Jose Sarte during the pre-trial on the determination of the disputed land area.
    • The judicial acceptability and binding nature of a compromise agreement (mis-termed as the Stipulation of Facts) in addressing land disputes.

Ruling:

  • (Subscriber-Only)

Ratio:

  • (Subscriber-Only)

Doctrine:

  • (Subscriber-Only)

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