G.R. No. 218236 - Sumifru Corp. vs. Spouses Cereno

The plaintiffs, Paulo Dilinila and Isabel Culatón, initiated an action in the Court of First Instance of La Union seeking to recover possession of a parcel of land and claim damages for its illegal detention.
The lower court ruled in favor of the plaintiffs, confirming their ownership and ordering the defendant to return the land.

In 1902 or 1903, the plaintiffs were involved in litigation in La Union with Geronimo and Isidro Ballas concerning the same piece of land.
The litigation concluded in favor of the plaintiffs, reinforcing their claim over the disputed property.
During the pendency of this litigation, the defendant, Manuel Sabado, rendered unspecified assistance to the plaintiffs.

As compensation for the defendant’s assistance during the earlier litigation, the plaintiffs turned over a portion of the land to him.
The agreement stipulated that the defendant would retain possession for three or four years while cultivating it to pay himself from its products.
Shortly after delivering the land, the defendant declared it for taxation purposes, implying an expectation of temporary possession.

After the expiration or during the term of the agreement, the plaintiffs demanded the return of the land, but the defendant refused to deliver possession.
At some point in 1907 or 1908, the plaintiffs declared the land for taxation and began paying taxes on it from 1910 onward, indicating a claim of renewed ownership.
Evidence, including an affidavit by both Paulo Dilinila and the defendant (Exhibit C), shows that in 1908 the defendant resold the land to the plaintiffs.
The defendant attempted to allege that the land had originally been sold to him in 1902 in satisfaction of a loan he had provided, a claim which the plaintiffs strongly denied.

The record presents conflicting evidence regarding the transaction: one party maintaining it was for compensation for assistance in litigation, and the other suggesting an earlier sale as settlement for a debt.
The overall evidence supports that the defendant either explicitly promised to return the land or, subsequently, resold it to the plaintiffs, thereby negating his right to withhold possession.

Whether the defendant’s retention of the land was justified under the circumstances of the agreement and subsequent actions.
Whether the agreement between the parties—regarding compensation for assistance and the temporary transfer of possession—obligated the defendant to return the land to the plaintiffs.
Whether the evidence supports the conclusion that the defendant’s later actions (including the declaration for taxation and the 1908 resale) were inconsistent with any claim of having acquired full title or an absolute right to retention.
How the conflicting assertions regarding the nature of the transaction (compensation for services versus sale in satisfaction of a debt) should be resolved in favor of determining rightful possession.