Facts:

The case involves Joaquin Cabrera and Juana Visitacion as petitioners against the Court of Appeals and several private respondents, including Felisa Gonzaga and other members of the Gonzaga family. The dispute centers on a parcel of land measuring 4,080 square meters located in Cainta, Rizal. This land was originally owned by Diego and Patricia Gonzaga, who acquired it in 1921, presumably using conjugal funds. After their deaths, the property was inherited by their grandchildren, the private respondents. The petitioners claim ownership through an alleged sale from Eliseo Gonzaga, one of the original owners' children, while the private respondents assert their rights through succession.

The tax declaration for the property was initially in the name of Diego and Patricia Gonzaga from 1921 until 1944, when it was transferred to Eliseo Gonzaga. In 1953, the tax declaration changed again, this time to Joaquin Cabrera. In 1970, the private respondents filed a complaint in the...

Facts:

Description and History of the Property

• The subject matter is a parcel of land comprising 4,080 square meters located in Cainta, Rizal.
• The property was originally owned by the spouses Diego Gonzaga and Patricia Gonzaga, who acquired it in 1921—presumably using conjugal funds.

Chain of Title and Tax Declarations

• The tax declaration on the land was originally issued in the names of the spouses Gonzaga from 1921.
• In 1944, the declaration was changed to the name of Eliseo Gonzaga, one of the spouses’ children.
• Later, in 1953, the tax declaration was modified once more, this time in the name of Joaquin Cabrera.

Parties to the Controversy

• Petitioners: Joaquin Cabrera and Juana Visitacion claimed ownership based on an alleged sale of the property by Eliseo Gonzaga.
• Respondents (Private Respondents): Heirs and grandchildren of the deceased original owners who asserted their right to the property by succession.

Procedural History and Litigation

• In 1970, the private respondents filed a complaint for recovery of the property, arguing that the petitioners had no right to it.
• The petitioners, in their answer, invoked the alleged sale by Eliseo Gonzaga and asserted possession of the property since 1944, even as the matter of registration under the Torrens system was concurrently pending in another court.
• Both parties referred to the pending registration proceedings, with petitioners contending that their ownership was validated by the registration and the respondents alleging that the registration was fraudulent.

Evidence and Testimonies

• For the private respondents, evidence included testimony from Conrado Cruz and Fernando Gonzaga, who testified about their continuous possession and inheritance through the family lineage.
• An amendment was made during trial correcting a typographical error in the complaint (changing “1960” to “1969”) regarding the discovery of a change in the tax declaration, which the defense did not object to.
• The petitioners presented Juana Visitacion (also the wife of Joaquin Cabrera) as the sole defense witness, along with documentation from a land registration case.

Allegations and Subsequent Motions

• The petitioners alleged that the property was transferred to them in a sale executed by Eliseo Gonzaga and that their continued possession since the alleged sale validated their title.
• The private respondents maintained that the property rightfully belonged to them by succession and demonstrated a continuous possession from the time their grandparents owned it.
• The petitioners also moved for reconsideration on the grounds of allegedly newly discovered evidence (two deeds of sale from 1944 and 1953) and conflicting testimonies (specifically, that of Conrado Cruz), but this motion was denied.

Issue:

Ownership and Transfer

• Whether the petitioners’ claim to the property based on an alleged sale by Eliseo Gonzaga is valid, or if the private respondents’ claim by right of succession prevails.

Prescription and Laches

• Whether the complaint for recovery of the property filed by the private respondents was barred by prescription or laches, considering the long delay between the alleged changes in the tax declarations and the filing of the complaint.

Nature of the Action

• Whether the action filed by the private respondents should correctly be characterized as an action for reconveyance under the applicable Land Registration Act, especially in light of the pending registration of the land.

Admissibility of Evidence

• Whether the petitioners’ newly discovered evidence (the deeds of sale) and the alleged conflicting or perjurious testimony of Conrado Cruz should have been considered, particularly given the timing and manner of their presentation.

Ruling:

• (Subscriber-Only)

Ratio:

• (Subscriber-Only)

Doctrine:

• (Subscriber-Only)