Galindez vs. Salamanca-Guzman

Facts:

Petitioners Rolando Galindez and Daniel Liberato (and persons claiming under them) sought review of the Court of Appeals (CA) Decision dated November 29, 2016 and Resolution dated March 31, 2017 in CA‑G.R. SP No. 144897 that reversed the Regional Trial Court’s (RTC) Joint Decision of May 11, 2015, which in turn had affirmed the Municipal Trial Court in Cities’ (MTCC) Joint Decision of November 7, 2014 dismissing respondents’ complaints for forcible entry.

Respondents — Felo mina Salamanca‑Guzman, Alejandro Collado, Vito M. Roldan, Erlinda M. Carino, and the Heirs of Flora Medriano Villasista (through attorney‑in‑fact Herminio Medriano) — filed five substantially identical complaints for forcible entry alleging that petitioners forcibly entered and fenced accretions attached to their titled lots in Barangay Palestina, San Jose City in November 2013, and prayed for ejectment of petitioners and those claiming under them. Respondents relied on title evidence, a sketch plan, barangay certifications (patunay), barangay blotter entries and judicial affidavits of themselves and several neighbors.

Petitioners answered with counterclaims, averring that the contested area was an independent lot long cleared and farmed by Vitaliano Ganado since 1967 and by petitioners as his farmhands since 1975 and 1990; they submitted affidavits, a sketch plan showing Ganado’s property and other documentary evidence. After failed mediation the parties submitted position papers and judicial affidavits.

The MTCC dismissed the forcible entry complaints for lack of cause of action, finding respondents failed to establish prior physical possession of the accretion and gave more weight to the testimonies of former and incumbent BARC chairpersons who declared that Ganado and petitioners had been in prior possession. The RTC, in its Joint Decision of May 11, 2015, affirmed the MTCC in toto, similarly discrediting respondents’ witnesses and finding petitioners’ evidence of prior possession preponderant. Respondents filed a notice of appeal to the CA.

Shortly after the MTCC decision (and one day after respondents’ notice of appeal), two second Judicial Affidavits of BARC chairpersons were filed with the MTCC; respondents also submitted on appeal a Supplemental Judicial Affidavit and an undated Certification of Engr. Bienvenido Magtuto identifying portions of the accretion allegedly belonging to each respondent. The CA reversed the RTC and MTCC, credited responden...(Pro-only)

Issues:

• Is the CA’s assailed Decision and Resolution contrary to law and jurisprudence?
• Is the CA’s assailed Decision supported by the evidence on record (i.e., did respondents prove prior physical possession by preponderance...(Pro-only)

Ruling:

• (Pro-only)

Ratio:

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Doctrine:

• (Pro-only)