G.R. No. 231508 - Galindez vs. Salamanca-Guzman

The case involves a petition for review on certiorari filed by petitioners Rolando Galindez, Daniel Liberato, and all persons claiming rights under them.
Respondents include Felomina Torres Salamanca‑Guzman, the heirs of Flora Medriano Villasista (represented by attorney‑in‑fact Herminio “Herman” Medriano), Erlinda M. CariAo, Vito M. Roldan, and Alejandro Collado.
The dispute originates from several complaints for forcible entry with prayer for a temporary restraining order and injunction, originally filed before the Municipal Trial Court in Cities (MTCC) and later consolidated in related civil cases.

The MTCC rendered a Joint Decision dismissing the complaints for lack of cause of action, noting that respondents failed to show evidence of prior physical possession of what they termed an “accretion” attached to their respective lots.
The Regional Trial Court (RTC) subsequently affirmed in toto the MTCC’s decision, emphasizing that the respondents’ testimonies were unconvincing and that petitioners had established prior physical possession by virtue of their long‑standing occupation and cultivation of the property.
Respondents’ evidence centered on documentary titles (e.g., various Transfer Certificates of Title), deeds, specialized power of attorney, and affidavits asserting that the contested property was an accretion attributable to the ownership of their adjoining lots.

Respondents claim that the accretion—amounting to approximately 9,535 sq.m.—belongs to the owner of the land by operation of law (under Article 457 of the Civil Code) and that their possession was continuous and rooted in the incorporation of the accretion into their properties.
Petitioners, on the other hand, argue that the contested property came into their actual physical possession when, via force, strategy, or stealth, they entered and cultivated the area by building fences and planting crops (notably onions).
The dispute primarily turns on proving “prior physical possession” as required in a forcible entry (or ejectment) case.

Shortly after the MTCC rendered its decision, respondents filed a second set of Judicial Affidavits from BARC Chairpersons Tangonan and Anastacio, as well as a Supplemental Judicial Affidavit and an undated Certification from Engr. Magtuto, during the appeal to the RTC and later to the Court of Appeals (CA).
The RTC, and subsequently parts of the record, noted that these submissions were irregular since they were filed after the deadlines prescribed by the Rules on Summary Procedure and were not by order of the court to clarify material facts.
Petitioners also submitted their evidence, including affidavits from Galindez, Liberato, and other witnesses, as well as documentary evidence such as TCTs, Sketch Plans, and police blotters, attesting to their continuous and prior occupancy of the contested property.

After the MTCC and RTC decisions favored petitioners based on the evidence of prior physical possession, respondents secured a reversal from the CA, which ordered petitioners to vacate the contested property.
The CA found that respondents had established their claim by adducing evidence—including the later‐filed affidavits and supplemental documents—that purportedly demonstrated prior possession.
Petitioners then elevated the case to the Supreme Court on the grounds that the CA’s decision was contrary to law, jurisprudence, and the preponderance of the evidence on record.

Whether or not the Court of Appeals’ (CA’s) decision and resolution, which reversed the Joint Decisions of the MTCC and RTC, were contrary to law and jurisprudence.

This issue involves the proper application of rulings on questions of law under Rule 45 and whether the CA exceeded its scope by delving into findings of fact where clear evidentiary rules should prevail.

Whether or not the CA’s decision is supported by the evidence on record, particularly regarding the submission and credibility of:

The second Judicial Affidavits of BARC Chairpersons Tangonan and Anastacio submitted after the MTCC’s decision.
The Supplemental Judicial Affidavit and undated Certification of Engr. Magtuto submitted only upon appeal.
The overall aggregate of evidence showing whether respondents or petitioners had prior physical possession of the contested property.