Title
Cansino vs. Court of Appeals
Case
G.R. No. 125799
Decision Date
Aug 21, 2003
Dispute over land possession; petitioners claimed public land use since 1977, respondents alleged ownership since 1964. SC ruled for petitioners, citing insufficient proof of prior possession and procedural errors in admitting new evidence.
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Case Digest (G.R. No. 125799)

Facts:

1. Background of the Case:

  • The case originated from a complaint for unlawful detainer filed by respondent spouses Francisco and Rosario Castro against petitioners Danilo Cansino, Linda de Jesus, and Elena Mesa. The subject of the dispute was a parcel of land located in Maligaya Park Subdivision, Kalookan City.

2. Allegations of the Respondents:

  • Respondents alleged that petitioners unlawfully constructed their houses on the land through "strategy and stealth."

3. Petitioners' Defense:

  • Petitioners claimed they believed the land was public property and had been in possession since 1977. They also questioned the jurisdiction of the Metropolitan Trial Court (MeTC) due to the respondents' failure to specify when their possession began.

4. MeTC Decision:

  • The MeTC dismissed the complaint, ruling that respondents failed to prove prior physical possession, which is essential in an ejectment case.

5. RTC Decision:

  • On appeal, the Regional Trial Court (RTC) initially affirmed the MeTC's decision but later reversed itself after respondents submitted additional evidence in a motion for reconsideration. The RTC found that respondents and their predecessors-in-interest had ownership and possession of the land since 1964, predating petitioners' possession.

6. Court of Appeals Decision:

  • The Court of Appeals upheld the RTC's decision, ruling that petitioners' possession was merely tolerated by the registered owners and that respondents had prior legal possession.

7. Supreme Court Petition:

  • Petitioners filed a petition for review on certiorari before the Supreme Court, raising issues regarding the admissibility of new evidence in a motion for reconsideration and the respondents' right to possess the land.

Issue:

  1. Admissibility of New Evidence in a Motion for Reconsideration:

    • Whether Section 5, Rule 135 of the Revised Rules of Court allows the introduction of new evidence in a motion for reconsideration, especially when such evidence was not part of the original trial.
  2. Right to Possess the Subject Land:

    • Whether the respondents have a clear right to possess the land, given the evidence presented and the procedural history of the case.

Ruling:

The Supreme Court reversed the decision of the Court of Appeals and reinstated the decisions of the MeTC and the RTC (prior to reconsideration). The Court held that:

  1. Admissibility of New Evidence:

    • The RTC erred in considering new evidence submitted in the motion for reconsideration. A motion for reconsideration cannot be used to introduce new evidence, as this violates due process. If respondents wanted to present new evidence, they should have filed a motion for a new trial based on newly discovered evidence.
  2. Prior Possession in Ejectment Cases:

    • In an ejectment case, the complainant must prove prior physical possession. Respondents failed to meet this burden, as their evidence of possession was insufficient and incomplete. The tax receipts and titles presented did not conclusively prove prior possession.
  3. Ownership vs. Possession:

    • The case was an ejectment case, and the issue of ownership should be resolved in a separate action. The only issue in this case was prior possession, which respondents failed to establish.

Ratio:

  1. Procedural Rules on Evidence:

    • A motion for reconsideration cannot be used to introduce new evidence. The proper remedy for presenting new evidence is a motion for a new trial based on newly discovered evidence, which must meet specific criteria (e.g., evidence must be material, discovered after trial, and likely to alter the result).
  2. Burden of Proof in Ejectment Cases:

    • In ejectment cases, the complainant must prove prior physical possession. Respondents failed to meet this burden, as their evidence was incomplete and did not cover the entire period of claimed possession.
  3. Separation of Possession and Ownership:

    • Ejectment cases are limited to the issue of possession. Questions of ownership must be resolved in a separate action. The Court emphasized that the case at bar was solely about prior possession, not ownership.
  4. Due Process in Judicial Proceedings:

    • Courts must adhere to procedural rules to ensure due process. Allowing new evidence in a motion for reconsideration without giving the opposing party an opportunity to contest it violates due process.

Conclusion:

The Supreme Court ruled in favor of the petitioners, reversing the Court of Appeals' decision and reinstating the earlier decisions of the MeTC and RTC. The Court emphasized the importance of procedural rules, the burden of proof in ejectment cases, and the separation of possession and ownership issues.


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