G.R. No. 209132 - Heirs of Villanueva vs. Heirs of Mendoza

The dispute arose between the heirs of Petronila Syquia Mendoza and the heirs of Teresita Villanueva over a lot located in Tamag, Vigan, Ilocos Sur.
The issue centers on conflicting claims regarding the ownership and boundaries of the subject property, with differing descriptions and measurements provided in various documents.

In 1992, Teresita Villanueva caused the survey and subdivision of the disputed property into two lots, namely Lot No. 5667-A and Lot No. 5667-B.
In 1994, Villanueva obtained a Free Patent over Lot No. 5667-B and was subsequently issued Original Certificate of Title (OCT) No. P-38444.
The complaint filed by the heirs of Syquia alleged that the title for Lot No. 5667-B was obtained through fraud and misrepresentation, asserting that they were in open, peaceful, and uninterrupted possession of the land for over 30 years.

On September 7, 2001, the heirs of Syquia filed a Complaint for declaration of nullity of free patent, reconveyance, and damages against Teresita Villanueva.
The Regional Trial Court (RTC) of Vigan City, Ilocos Sur, in its December 14, 2006 decision (Civil Case No. 5649-V) dismissed the complaint for failure to prove the cause of action and for being barred by laches.
The heirs of Syquia appealed to the Court of Appeals (CA), which initially affirmed the RTC decision on November 29, 2011.
Upon filing a Motion for Reconsideration, the CA, on August 29, 2013, reversed its prior ruling and set aside the RTC decision, declaring the free patent and subsequent derivative titles null and void, and ordering their cancellation.

Multiple documents presented by the heirs of Syquia exhibited significant discrepancies:

The complaint identified the property as Lot No. 5667 with an area of 9,483 square meters.
A tax declaration cited in support mentioned an area of 5,931 square meters.
The free patent obtained by Villanueva covered Lot No. 5667-B, which measured only 4,497 square meters.

The boundaries described in the tax declaration differed from those in the cadastral survey and the free patent:

The tax declaration referred to boundaries identifying different adjacent lots (e.g., Lot No. 5663, Lot No. 5666, and Lot No. 6167) and stated landmarks that did not consistently match those in the subdivision.
The CA relied on documents such as B.L. Form No. V-37, a Sketch Plan, and a Relocation Plan to establish metes and bounds, yet failed to reconcile the disparities in lot area and boundary descriptions.

The heirs of Syquia did not provide sufficient proof that the property as described in the tax declaration corresponded with either the subdivided Lot No. 5667-B or the original Lot No. 5667 as shown in the cadastral survey.
No adequate explanation was given for the substantial discrepancy in area measurements, nor was there evidence to link the boundaries of the tax declaration with those of the free patent.
Additional evidence, including the Final Project of Partition from 1950, failed to resolve the differences, rendering the claim of precise identification of the subject property unsubstantiated.

Whether or not the heirs of Syquia are entitled to recover the subject property from the heirs of Villanueva.

Whether the discrepancies in the description, area, and boundaries of the property—across the tax declaration, cadastral survey, and free patent—affect the claim for recovery.
Whether the evidence submitted by the heirs of Syquia sufficiently establishes a clear and definitive identification of the property in issue.
Whether the appellate courts, in reviewing a petition under Rule 45, should venture into questions of fact or restrict themselves to errors of law.

Whether the Supreme Court should re-examine the factual determinations made by the trial court, given that its function in a petition for review on certiorari is strictly limited to reviewing questions of law, not questions of fact.