G.R. No. 5002 - Belen vs. Belen

Plaintiffs: Martin Belen and Honoria Belen (minors) – Honoria was assisted by her husband, Segundo Capuno.
Guardian ad litem: Gerardo Belen was appointed to represent the minor plaintiffs in the trial.
Defendant: Alejo Belen, who later became involved in the possession of the disputed lands.

Getulio Belen, during his marriage to Juliana Fanoy (residents of San Pablo), had two children: Marciana and Feliciano Belen.
The spouses acquired substantial property (including two parcels of land planted with around 600 cocoanut trees each) using conjugal funds.
Getulio Belen inherited a smaller tract of land from his father, described with specific boundaries related to properties owned by Cornelio Belen, Venancio Alimon, Geronimo Sahagun, and Faustina Belen.

Planted with 600 cocoanut trees in the barrio of Santa Maria Magdalena, San Pablo.
Bounded by the lands of Cornelio Belen (north), Venancio Alimon (east and south), and lands of Venancio Alimon, Geronimo Sahagun, and Faustina Belen (west).

Also planted with 600 cocoanut trees situated in the same barrio.
Bounded by the properties of Lucas Baldovino and Alejo Belen (north), allegedly Alejo Belen’s land (east), and lands belonging to Alejo Belen and Maria Belen (south), with other boundaries to Pedro and Francisco Pandifio (west).

Prior to October 1888: Acquisition of real property by family members using conjugal funds.
October 19, 1888: Getulio Belen died intestate, giving rise to issues of succession.
September 17, 1890: Juliana Fanoy married Gerardo Belen, thereby producing children Honoria (born November 20, 1890) and Martin (born November 10, 1892).
July 15, 1895: Death of Juliana Fanoy left four heirs (Marciana, Feliciano, Honoria, and Martin), though Marciana and Feliciano later died without succession in 1900 and 1902 respectively.
1902: Defendant Alejo Belen took possession of the two disputed parcels without existing title or right, and, thereafter, refused to return or account for the fruits and profits derived from the lands.

Demand: Plaintiffs sought a declaration affirming their exclusive ownership of the lands and pleaded for the return of the properties plus P4,000 in fruits and profits from 1902 until the filing of the complaint.
Defendant’s Demurrer: The defendant’s demurrer was overruled. In his answer, he denied all allegations and presented special defenses:

Claimed ownership of two parcels of land in Santa Maria Magdalena based on inherited titles – one from his mother, Valeria Alcantara, and the other from his father, Facundo Belen.
Asserted that the plaintiffs had no right of action over the properties since he held them under titles of ownership.

Lower Court Decision: On March 10, 1908, the trial court rendered judgment absolving the defendant with costs against the plaintiffs.
Motion for New Trial: The plaintiffs, upon receiving the judgment, moved for a new trial claiming that the outcome was contrary to the weight of evidence; however, the motion was overruled, and exceptions were duly noted.

Whether the plaintiffs satisfactorily proved their ownership and prior possession of the disputed lands.
Whether they established that their possession was lost in the extraordinary manner they alleged.

Whether the defendant’s possession of the lands, under his claim of title from inheritance and purchase, constitutes a better right than that alleged by the plaintiffs.
Whether the legal presumption afforded to possession under Articles 440 and 448 of the Civil Code applies in this case.

Whether the plaintiffs met their burden of evidence in proving the facts upon which their claim was based.
Whether the preponderance of evidence conclusively favored the defendant’s possession and title.

Whether the defendant’s assertion as to his ownership based on inheritance and earlier transactions is legally tenable.
Whether the deficiencies in the plaintiffs’ presentation of evidence justify the ruling in favor of the defendant.