G.R. No. L-50420 - Ferrer-Lopez vs. Court of Appeals

Petitioners are the heirs of the late Dominga Velasco Vda. de Ferrer, inheriting what is claimed to be a 44-hectare portion of a 54-hectare landholding originally registered as Lot 12509 of the Malasiqui cadastral survey.
Private respondents include Tomas Maningding, Sp. Maria Nieves Puzon, spouses Fermin Peralta and Juliana Puzon, and Honorata Puzon, who, through transactions and cadastral proceedings, hold Original Certificate of Title (OCT) No. 13505 covering Lot 12510 in Pangasinan.

The original property owned by the petitioners’ mother was subdivided during the cadastral process into multiple lots (12509-A, 12509-B, 12509-C, 12509-D, 12509-E, and 12509-F).
Petitioners assert that after selling 10 hectares, they inherited the remaining 44 hectares, while respondents claim rights over a distinct portion represented by Lot 12510, described as having an area of approximately 52,908 sq. m. or 5.3408 hectares.
Several documents were introduced by the parties, including notarial register entries, tax declarations, realty tax receipts, and a court-appointed commissioner’s report with a rectified sketch indicating the physical boundaries of the disputed lots.

Petitioners contend that a portion measuring more than 2 1/2 hectares of their inherited land has been encroached upon by the private respondents.
It is alleged that during the cadastral survey, Ramon Puzon, acting as both overseer of Dominga Velasco’s property and administrator for the lot later acquired by the respondents, intentionally deviated the boundary line away from the barrio road for over one kilometer toward the north.
The petitioners claim these actions adversely affected the boundary that rightfully belonged to their mother’s estate.

The private respondents initiated legal proceedings by filing a complaint on October 16, 1967, in the Court of First Instance of Pangasinan, alleging encroachment and asserting their title based on a void and ineffective claim of ownership in the petitioners’ land.
Pre-trial proceedings were held on four separate dates (March 18, 1968; July 15, 1968; September 30, 1968; December 9, 1968) during which requests for admission and evidence presentation were made by both parties.
At trial, the court determined in favor of the private respondents, ordering the petitioners to vacate the encroached area and awarding attorney’s fees and costs to the respondents.
The Court of Appeals confirmed the trial court’s decision, leading the petitioners to elevate the case by certiorari to the Supreme Court.

Petitioners presented exhibits such as a notarial register (Exhibit 1), minutes of a cadastral hearing (Exhibit 2), and tax declarations (Exhibit 3) to support their claim over the disputed boundaries and to challenge the area recorded in the respondents’ OCT.
Private respondents countered with OCT No. 13505, detailed cadastral descriptions, and the testimony of Engineer Miguel Mamaril regarding the physical boundary markers, notably the earth dikes corresponding to cadastral monuments.
A dispute also arose over the alleged dual role of Ramon Puzon, with petitioners alleging a conflict of interest, while respondents maintained that no such conflict existed and that the administrative functions were clearly demarcated for the separate lots.

Whether the respondent court erred in its application and interpretation of Rule 26 of the Revised Rules of Court concerning requests for admission made during pre-trial proceedings.
Whether the evidence established proves that private respondents were not in actual, continuous, and exclusive possession of the more than 2 1/2 hectares of the disputed land prior to 1967.
Whether the physical and actual boundary, as determined by the trial court’s commissioner through an ocular inspection and the accompanying sketch, was correctly ascertained and considered by the lower courts.
Whether the petitioners’ claim of an “implied trust”—asserting that conflicting interests arose from Ramon Puzon’s dual roles—has any valid legal basis in the present case.
Whether the petitioners’ assertion of acquisitive prescription may prevail over the conclusive effect of the registered title (OCT No. 13505) held by the private respondents.