Case Digest (G.R. No. 247806) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In Cequena v. Bolante, G.R. No. 137944, decided April 6, 2000, the petitioners Fernanda Mendoza Cequena and Ruperta Mendoza Lirio, daughters of the late Margarito Mendoza, sought to recover a 1,728-square-meter parcel in Barangay Bangad, Binangonan, Rizal, originally taxed under Tax Declaration No. 26-0027. Prior to 1954, the lot was declared in the name of Sinforoso Mendoza, father of the respondent, Honorata Mendoza Bolante, who died in 1930. Relying on a 1953 affidavit, petitioners’ father, Margarito, had the tax declaration switched to his name; his heirs thereafter paid realty taxes until 1979. Respondent and her illiterate mother meanwhile occupied and cultivated the land continuously from the 1930s, paying taxes from 1932 to 1948. A cadastral survey in October 1979 revealed a boundary dispute between respondent and Miguel Mendoza, petitioners’ brother. At the Regional Trial Court, petitioners prevailed and obtained an order declaring them owners, ejecting respondent, awar Case Digest (G.R. No. 247806) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Parties and Subject Matter
- Petitioners Fernanda Mendoza Cequena and Ruperta Mendoza Lirio are daughters and heirs of Margarito Mendoza.
- Respondent Honorata Mendoza Bolante is the daughter and heir of Sinforoso Mendoza.
- The property is a 1,728-square-meter lot in Barangay Bangad, Binangonan, Rizal, covered by Tax Declaration No. 26-0027.
- Ownership and Tax Declarations
- Prior to 1954 the lot was declared in the name of Sinforoso Mendoza (d. 1930).
- On affidavit, the tax declaration was later cancelled and re-declared in the name of Margarito Mendoza, Sinforoso’s brother.
- Petitioners produced tax declarations and receipts for years 1953–1979 in Margarito’s name.
- Respondent produced tax receipts from 1932–1948 in her father’s name and later in her own name.
- Possession and Dispute
- Both branches of the Mendoza family concurrently occupied and tilled parts of the lot until 1985.
- Respondent and Miguel Mendoza (petitioners’ brother) disputed ownership during the cadastral survey of October 15, 1979.
- In 1985, respondent physically ousted Miguel Mendoza and maintained exclusive possession.
- Trial Court and Court of Appeals Decisions
- The Regional Trial Court declared petitioners owners, ordering respondent to vacate and pay damages.
- The Court of Appeals reversed, finding the key affidavit unauthenticated and respondent the preferred possessor under Art. 538, Civil Code.
Issues:
- Admissibility and Probative Value of the Affidavit
- Whether the cancellation affidavit transferring the tax declaration from Sinforoso to Margarito is admissible despite the affiants’ non-presentation.
- Whether the affidavit is an exception to hearsay as a declaration against interest or an ancient document.
- Preference and Character of Possession
- Whether respondent’s possession since 1985 is public, adverse, peaceful, exclusive, and continuous, making her the preferred possessor.
- Whether petitioners’ possession, begun in 1952, is superior or rights were lost by force.
- Ripening of Possession into Ownership
- Whether respondent’s uninterrupted possession since 1932, with tax declarations and payment, ripened into ownership by acquisitive prescription (Art. 1134, Civil Code).
- Whether petitioners’ occupation for over thirty years, without hostility or exclusive possession, acquired ownership.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)