G.R. No. 12155 - People vs. Eduave

Lot No. 2749 in Atimonan, Quezon was the subject of cadastral proceedings before the Court of First Instance of Quezon, Gumaca Branch.
Miguel Escritor Jr. filed an answer declaring ownership, claiming acquisition by inheritance from his deceased father.

Notice of hearing was published and an order of general default entered as no opposition appeared.
On May 15, 1958, the Court rendered a decision in Cadastral Case No. 72, adjudicating ownership of Lot No. 2749 and its improvements in favor of Escritor, confirming his title.
Escritor took possession of the property immediately thereafter.
On July 15, 1958, the Court ordered the issuance of a decree of registration in favor of Escritor, declaring the decision final.

On August 2, 1958, Simeon S. Acuna filed a petition for review alleging the decision was obtained through fraud and misrepresentation.
The petition was granted on July 18, 1960, and a new hearing scheduled for September 13, 1960.
Miguel Escritor died during the proceedings; his heirs (petitioners herein) continued possession.

On February 16, 1971, the Court ruled in favor of Acuna, adjudicating Lot No. 2749 to him and ordering the petitioners to vacate.
Petitioners voluntarily surrendered possession following issuance of writ of possession.
On October 13, 1975, Acuna filed Civil Case No. 1138-G for recovery of damages against petitioners for the fruits of the land allegedly possessed unlawfully for 13 years.
The lower court dismissed Acuna’s damages complaint, ruling petitioners possessed under good faith and just title, and cause of action had prescribed.
The Intermediate Appellate Court reversed the dismissal on October 31, 1984, holding petitioners liable for damages as possessors in bad faith.

The appellate court relied on the cadastral court's statement that Miguel Escritor forcibly took possession and benefited from the property, concluding petitioners had unlawful possession from 1958 to 1971.
Based on this finding, the court ordered petitioners to pay damages for fruits, attorney’s fees, and costs.

Petitioners argued they were possessors in good faith and the registration was attained lawfully with proper notice and proceedings.
Supreme Court noted:

The 1958 cadastral decision was final and adjudged the lot to Escritor after due process.
No evidence showed Escritor knew of title defects, thus possession was in good faith.
Bad faith is personal and not transmissible to heirs; petitioners had no actual knowledge of any defect or fraud.
Respondent Acuna failed to prove fraud in cadastral proceedings or bad faith on petitioners’ part.
The allegation of fraud was unsupported since Acuna himself failed to appear at the hearings due to a misunderstanding with his lawyer, not because of any acts by petitioners.

Whether petitioners are liable for damages for possession of Lot No. 2749 from 1958 to 1971.
Whether petitioners’ possession was in bad faith, justifying Acuna’s claim for recovery of fruits.
Whether bad faith in possession is transmissible to heirs.
Whether there was fraud or misrepresentation in the cadastral proceedings that would invalidate the registration of the property in favor of Escritor.