G.R. No. L-1716 - Material Distributors , Inc. vs. Natividad

The litigation involves plaintiffs Bernardino Cacnio et al. and defendant Lazaro Baens regarding title and possession of several tracts of land located in the barrio of Hulong Duhat in the town of Tambobong.
The plaintiffs claimed to be the absolute owners of their respective building lots, which they inherited from their parents who had possessed the land for over forty years.
The defendant, Baens, initiated an action in the court of the justice of the peace to recover these parcels of land, contesting the plaintiffs’ assumption of ownership.

In the lower court, a judgment was rendered in favor of the defendant, which the plaintiffs appealed to the Court of First Instance.
The plaintiffs sought not only a declaration of ownership and possession of the disputed lots but also damages amounting to 600 dollars, an order for costs, and a preliminary injunction to stop further ejectment proceedings.
A motion was made by plaintiffs to amend a paragraph in the complaint to clarify that their right to the land originated from inheritance from their father, Severino de la Cruz, and his wife, Bernardina Cacnio.
The defendant affirmed his prior general and specific denials of the allegations and maintained that he had acquired the land by composition with the Government.

The defendant presented title deeds issued by the Direccion General de Administration Civil on October 25, 1891, evidencing his ownership of a larger tract of land within which the disputed parcels were included.
These deeds were duly recorded in the Registry of Property on November 14, 1891, a fact both admitted in the record and uncontested by the plaintiffs aside from disputing its substance.
Counsel for the plaintiffs impugned the probative force of the defendant’s documentary evidence but did not challenge the materiality or registration of these public instruments.

The plaintiffs failed to timely take exception to the court’s order of October 30, 1903, denying their motion for a new trial as required under paragraph 3, Section 497 of the Code of Civil Procedure.
The issue of whether the documentary evidence—in the form of a duly recorded public deed—could be overcome by the plaintiffs’ parol evidence claiming acquisition of title by extraordinary prescription under Article 1959 of the Civil Code was central to the dispute.

Which party possesses the better title to the disputed land?
Whether the defendant’s recorded deed, issued by the Direccion General de Administration Civil and recorded in the Registry of Property, has a superior legal basis compared to the plaintiffs' claim of title by virtue of inheritance and long possession.

Whether public instruments, properly executed and recorded, are admissible and determinative against the claims of parties who did not participate in their execution.
If the plaintiffs’ parol evidence concerning extraordinary prescription is sufficient to defeat the defendant’s right based on a valid deed and its registration.

The impact of the plaintiffs’ failure to file a timely exception to the new trial motion on the appellate review of the evidence.
Whether this lapse prevents a reconsideration of the factual findings and conclusiveness of the lower court’s judgment.