Title
Guido vs. De Borja
Case
G.R. No. 4013
Decision Date
Feb 4, 1909
Heirs of Guido and Santa Ana successfully reclaimed ownership of Angono hacienda from tenants-turned-claimants, affirmed by court based on historical titles and valid ownership claims.
heirs
ownership
possession
A

Case Digest (G.R. No. 4013)

Facts:

  • Initiation of the suit for recovery of ownership and possession
  • The heirs and successors of Francisco Guido and Dominga Santa Ana instituted an action to recover ownership and possession of the hacienda of Angono.
  • The defendants were tenants of the hacienda until the year 1903.
  • After 1903, the defendants denied the plaintiffs’ ownership and pretended to be owners of the hacienda.
  • Judgment of the Court of First Instance of the Province of Rizal
  • The trial court ordered the defendants to restore possession of the hacienda to the plaintiffs and to Justo Guido, Juliana Guido, Buenaventura Guido, and other participants shown in the amended complaint.
  • The trial court ruled that the fruits or crops and plantings of the defendants on the hacienda did not belong to the plaintiffs.
  • In lieu of restitution of crops and plantings, the trial court ordered each defendant to pay the plaintiffs and their participants sums in money and paddy corresponding to amounts itemized in statements attached to the complaint (statements numbered 1, 2, 3, and 4).
  • The trial court held that costs of the suit should be paid by the defendants.
  • Errors assigned on appeal by the defendants and appellants
  • The defendants raised five assigned errors.
  • The first two errors were procedural or formal.
  • The last three errors attacked the merits: proof of ownership, proof of defendants’ status as tenants/lessees on shares, and proof of defendants’ indebtedness for ground rent or lease on shares.
  • Third error: challenge to plaintiffs’ ownership and possession (documentary evidence and reliance on “third persons”)
  • The appellants relied on documentary evidence (Exhibits A, B, C, 6, 7, 8, 9, and D) described as principally constituting the appellees’ titles of ownership.
  • The appellants asserted that the hacienda should be viewed as divided into two halves:
1) one-half derived from Francisco Guido, and 2) one-half derived from Dominga Santa Ana.
  • The appellants attacked the titles by claiming that:
1) the grant to General Don Domingo Antonio de Otero Bermudez had been made in violation of laws cited as laws 7 and 8, title 12, book 3 [4], Recopilacion de las Leyes de Indias, to the prejudice of inhabitants of Angono (described as Indios); 2) later issuance, with royal approval, to Alferes Real Don Andres Blanco Berinudez as successor was allegedly issued without prejudice to third persons who might show a better right; 3) the appellants invoked article 23 of the Mortgage Law to argue that unregistered instruments cannot prejudice third persons.
  • The appellants further argued that for the half derived from Francisco Guido:
1) that half was allegedly not entered in the registry of property; and 2) thus, titles allegedly could not prejudice third persons under the Mortgage Law.
  • The appellants further argued that for the half derived from Dominga Santa Ana:
1) although possession was allegedly registered, registration dated only from 15 July 1899; and 2) the appellants contended that registration of possession could not ripen into ownership except after twenty years under article 393 of the Mortgage Law; hence, current title was allegedly not yet one of ownership.
  • The appellants also invoked the historical origin of the hacienda title:
1) the original title to the whole hacienda of Angono was issued by composicion with royal approval on 16 December 1749 and 15 September 1752; 2) the first order and the second order were presented in the decision, including language confirming the legitimacy of the titles and issuing confirmation; and 3) both orders contained a clause that the confirmation would be observed “Provided, however, That they shall not prejudice third persons having a better right.”
  • Appellees’ ownership reliance and the Court’s discussion of the historic orders and later royal confirmation
  • The Court treated the absolute ownership granted to Otero and Blanco as fully proven, based on the orders and their confirmations.
  • The Court treated the titles as made final by virtue of the real cedula of 15 October 1754, article 5, which the decision quoted in full, including the scheme of non-molestation and later confirmation after examination for fraud or collusion and equitable price.
  • The Court held that the clause “without prejudice to third persons who may prove a better right” did not allow the Angono residents, including the defendants, to defeat the grantees’ successors, for lack of a better right.
  • The Court noted that the natives or residents of Angono could not be “persons with a better right” because:
1) they were part of the same estancia/hacienda and were tenants with only precarious rights against the owners at the relevant time; and 2) like the Binangonan residents described in the judgment, they had allegedly not been able to produce their own title of ownership or possession even up to the time of the appealed judgment.
  • The Court also stated that if any right existed, it could allegedly be exercised only through mechanisms prescribed by article 8 of the royal decree of 26 January 1889 and article 5 of the royal decree of 26 October 1881, which the Court described as directing claims against the administration and not against the land grantees.
  • The Court discussed that, for the Francisco Guido half, the appellants’ invocation of “third persons” under the Mortgage Law reflected an alleged confusion between:
1) “third persons” of the civil law, and 2) “third persons” of the Mortgage Law.
  • The Court explained that the Mortgage Law protections were said to apply only within the scope of its purpose—protecting registered rights against those who do not register—and not to a situation where the contesting party did not have and did not claim a registered real right.
  • Fourth and Fifth errors: tenant status and indebtedness for ground rent or lease on shares
  • The Court ruled that the trial court did not err in considering all appellants as tenants or lessees on shares of the hacienda of Angono.
  • The Court also ruled that the trial court did not err in considering that the appellants owed the appellees the amounts for ground rent, tenancy, or lease on shares, as itemized in statements numbered 1, 2, 3, and 4 attached to the complaint.
  • The appellants’ challenge allegedly rested on a claimed lack of identity: some defendants allegedly were not shown by proof to be tenants.
  • The decision noted that of 155 defendants, 51 were shown by documentary evidence to be tenants: those defendants allegedly subscribed to proceedings served in February 1898 to compel them to deposit what they owed for ground rent/tenancy/lease on shares.
  • For the remaining defendants, the Court held that the claim of tenant identity was not fully proven except by testimony of one witness and the statements attached to the complaint.
  • The Court held that the appellees’ answer contained a conclusive reason: the identity issue was treated as immaterial because all defendants appeared and answered the complaint by the same names as in the complaint, without raising any name issue in the court below.
  • First error: propriety of joinder of all defendants
  • The appellants argued they were not united in one sole contract, so they could not be sued jointly; they claimed separate and distinct causes of action because each defendant held different parcels.
  • The Court rejected the argument and held that the joinder was based on unity of:
1) action, 2) object, and 3) d...(Subscriber-Only)
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