G.R. No. 175188 - Commissioner of Internal Revenue vs. La Tondena Distillers, Inc.

Petitioner Elsie N. Belmonte claimed ownership over an unregistered parcel of land located in Barangay Concepcion, Aroroy, Masbate, which she maintained was inherited from her father through a Deed of Absolute Sale and later consolidated by her mother’s Deed of Quitclaim.
The property, as per petitioner’s documents, was described as a three (3) hectare land bounded by specific neighboring lots identified by the names Lumangaya, Ortinero, G. Magas, and Rodolfo Belmonte, and was declared under Tax Declaration No. 2802.

In May 2006, respondents allegedly employed force, intimidation, and threat to dislodge petitioner and her relatives from the subject property, thereby depriving her of its possession and use.
In response, petitioner filed a Complaint for Recovery of Possession and Ownership of Land with Damages before the Municipal Circuit Trial Court (MCTC) in Aroroy-Baleno, seeking recognition of her title and an order for respondents to vacate the property.

The MCTC, after weighing the evidence—which included a court-commissioned Survey Report by Engr. Reyes that revealed discrepancies in the described area and boundaries—dismissed petitioner’s complaint for lack of cause of action.
Petitioner’s survey report indicated a three-hectare area, while the verification survey by Engr. Reyes, based on a different tax declaration (No. 6201), suggested an area of approximately 4.155 hectares, highlighting significant inconsistencies.
Petitioner appealed the dismissal before the Regional Trial Court (RTC) of Masbate City, Branch 47, which reversed the MCTC ruling and declared her as the lawful owner and possessor of the subject property, also awarding damages and litigation expenses.
Respondents, arguing that the property described by petitioner was distinct from the one in their possession (characterized by different area and boundaries as per Tax Declaration No. 013-0017), petitioned for review before the Court of Appeals (CA).

The CA, in its Decision dated January 30, 2018, reversed the RTC ruling and reinstated the MCTC decision on the ground that petitioner failed to satisfy the essential requirement of clearly identifying the subject property.
In a subsequent Resolution dated June 27, 2018, the CA denied petitioner’s Motion for Reconsideration, holding that the disparities in the technical description, area, and boundary details between petitioner’s documents and the respondents’ tax declarations proved the existence of two distinct properties.

Whether the Court of Appeals gravely erred in ruling that petitioner failed to prove her title to the subject property.

Whether the petitioner sufficiently identified the property through a technical description detailing its location, area, and boundaries as required under Article 434 of the Civil Code.
Whether the discrepancies in the area and boundaries between petitioner’s tax declaration (3 hectares) and the respondents’ property (approximately 4.2118–4.155 hectares) invalidate her claim to recover possession and ownership.
Whether the conflicting evidentiary submissions—particularly the Survey Report by Engr. Reyes based on a different tax declaration—justify the dismissal of petitioner’s complaint.