G.R. No. L-20617 - Garcia vs. Anas

On August 3, 1957, Dalmacio Anas filed a complaint for forcible entry before the Justice of the Peace Court of Zablan, Mt. Province.
The complaint prayed that Bruno Garcia be ordered to deliver the possession of the land in controversy to the plaintiff.

Plaintiff alleged that he was dispossessed of a particular parcel of land.
Defendant Bruno Garcia contended that the land, which plaintiff claimed, was part of a parcel inherited from his father.
Garcia maintained that he had continuously possessed the land without disturbance or dispossession by any party.

The Justice of the Peace dismissed the complaint, holding that defender was entitled to the possession of the land.
On appeal, the Court of First Instance of Baguio similarly dismissed the complaint, basing its decision on the plaintiff’s failure to clearly identify the specific parcel of land allegedly dispossessed.

The Court of Appeals found the plaintiff’s complaint to be meritorious and reversed the lower court rulings.
It determined that the plaintiff was the rightful and sole owner, having acquired 4 hectares of land from Pablo Galbo in 1945 and subsequently expanding his possession through a patent covering an additional 6 hectares.
The Court emphasized that in May 1957, the defendant had encroached upon the land by surveying, fencing it, and placing his carabao there, thereby disturbing the plaintiff’s possession.
Based on these findings, the Court of Appeals ordered the defendant to restore the plaintiff’s possession of the land and to pay him P500.00 as attorney’s fees.

The case was elevated to the Supreme Court on a petition for review.
The court-a-quo (the trial court) had dismissed the complaint on the ground that the plaintiff failed to precisely identify the land, partly due to conflicting testimony (e.g., Rosita Gayo’s varying descriptions of the land’s extent).
In contrast, the Court of Appeals underscored the factual evidence of the plaintiff’s actual, uninterrupted possession and the defendant’s subsequent disruptive actions.

Whether the plaintiff had sufficiently established his claim to possession despite discrepancies in identifying the exact boundaries or extent of the land.

The issue centered on the adequacy of the evidence regarding the precise identification of the land.
It questioned whether conflicting descriptions by a key witness should preclude the recovery of possession.

Whether, in an ejectment action, the proof of de facto possession outweighs the necessity to prove title or clear ownership.

The issue examined if the action for ejectment should be decided based solely on physical possession rather than on title or ownership disputes.
It involved determining if prior possession, once disturbed by force or encroachment, necessitates restoration regardless of title claims.

Whether the procedural approach of the lower court (focusing on title evidence) was appropriate in an action fundamentally concerned with de facto possession.