Title
Baluyo y Gamora vs. Spouses De la Cruz
Case
G.R. No. 197058
Decision Date
Oct 14, 2015
Gregory Baluyo claimed prior possession of a property via a Deed of Absolute Sale; respondents contested ownership. SC ruled in favor of Gregory, reinstating possession, while allowing separate ownership disputes.

Case Digest (G.R. No. 217428)
Expanded Legal Reasoning Model

Facts:

  • Background of the Case
    • In May 2008, Gregory G. Baluyo, on behalf of his brother Emmanuel Baluyo, filed a complaint for forcible entry against spouses Joaquin and Rebecca De La Cruz.
    • The complaint sought not only possession of a residential house and lot in Barangay San Pablo, Calabanga, Camarines Sur, but also preliminary mandatory injunction, damages, and attorney’s fees.
    • The property in dispute was originally owned by Bonifacio and Consolacion Dimaano and later acquired by Emmanuel Baluyo through a Deed of Absolute Sale executed on November 30, 1999.
  • Allegations and Claims
    • Petitioner’s Allegations
      • The petitioner alleged that he had been the caretaker and had actual, prior physical possession of the subject property, having resided there since childhood with his family.
      • It was claimed that the residential house was leased to Lourdes Perico and that on April 23, 2008, the respondents, through force and intimidation, demolished the house, forcibly evicting the lessee and depriving the petitioner of his possession.
      • Petitioner relied on the notarized Deed of Absolute Sale as evidence of his right and prior possession.
    • Respondents’ Defense
      • The respondents asserted that the property was actually owned by Bonifacio Dimaano, with respondent Rebecca being his sole heir via the Original Certificate of Title No. 31756.
      • They challenged the petitioner’s claim of a valid lease with Perico, alleging that the lessee neither paid rent nor was forcibly ejected from the property.
      • The respondents questioned the authenticity and specificity of the property described in the Deed of Absolute Sale, suggesting that only a “1/2 portion” of the 428.27 square meters was conveyed.
  • Procedural History
    • Municipal Trial Court (MTC) Decision
      • On February 26, 2009, the MTC of Calabanga, Camarines Sur ruled in the petitioner’s favor ordering the respondents to surrender possession and pay damages as well as attorney’s fees.
    • Regional Trial Court (RTC) Affirmation
      • The RTC affirmed the MTC’s ruling in its entirety, upholding the validity of the Deed of Absolute Sale and the petitioner’s claim of prior possession.
    • Court of Appeals (CA) Reversal
      • On October 22, 2010, the CA reversed the RTC’s decision, holding that the petitioner failed to establish his prior physical possession.
      • The CA found that the petitioner did not sufficiently identify the specific portion of the property conveyed to him, which is critical as an indispensable element in a forcible entry action.
    • Petition for Review on Certiorari
      • Following the denial of his motion for reconsideration by the CA, the petitioner elevated the case to the Supreme Court via a petition for review on certiorari under Rule 45.
  • Issues Raised by the Parties
    • The petitioner contended that the CA misapprehended the facts regarding his prior physical possession, arguing that his family had resided in the property since 1970 and that the property conveyed was clearly identifiable as the remaining half of the lot.
    • The respondents maintained that the petitioner’s evidence, particularly the notarized deed and affidavits, was self-serving and uncorroborated, thereby failing to prove lawful possession.
  • Evidentiary Submissions
    • Petitioner’s Evidence
      • A notarized Deed of Absolute Sale (executed on November 30, 1999 by Atty. Leoncio F. Elopre) purportedly transferring a half-portion of the property to Emmanuel Baluyo.
      • Affidavits of witnesses who attested to the longstanding possession and occupancy of the property by the Baluyo family.
    • Respondents’ Evidence
      • The respondents questioned the authenticity of the petitioner’s deed by referring to a related instance of alleged forgery in another sale transaction.
      • They also challenged the claim by arguing that the subject deed surfaced only nine years after its purported execution and argued that it might not have been duly notarized.

Issues:

  • Whether the petitioner sufficiently established his prior physical possession of the subject property as required in a forcible entry action.
    • Whether the evidence submitted, including the notarized Deed of Absolute Sale and witness affidavits, adequately proved possession.
    • Whether the petitioner’s claim is strengthened by longstanding residency and the manner in which the property was occupied.
  • Whether the specific identity and demarcation of the “half-portion” of the property conveyed to the petitioner was properly established.
    • Analysis of the property description in the deed versus the actual physical boundaries of the residential lot.
    • Evaluation of the consistency between lower court proceedings and the contested deed’s details.
  • Whether the respondents’ challenges regarding the validity of the notarized deed, including allegations of forgery and lack of notarization, undermine the petitioner’s claim.
    • Consideration of the presumption of regularity accorded to notarized documents.
    • The impact of the evidence concerning past allegations of forgery in a separate transaction.
  • Whether the CA erred in reversing the RTC’s decision in light of the evidence presented and the legal requirements for establishing forcible entry.

Ruling:

  • (Subscriber-Only)

Ratio:

  • (Subscriber-Only)

Doctrine:

  • (Subscriber-Only)
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