Case Digest (G.R. No. L-45159)
Facts:
The case involves Jose Hermo as the petitioner and the Honorable Court of Appeals, Andres Floresca, and Isidro Fulgueras as respondents. The dispute arose from an action to quiet title filed by Hermo against Floresca and Fulgueras in the Court of First Instance of Sorsogon. The parties were occupants of adjacent parcels of land, and the contention centered on a disputed area that both claimed to have superior rights over. A relocation survey conducted by a court-appointed commissioner revealed that the contested area measured 11,122 square meters, significantly larger than the initially estimated 3,500 square meters. Following this, Hermo sought to amend his complaint to reflect the accurate area, which the court granted without objection from the respondents.
Hermo's claim to the land was based on several documents: (1) a Deed of Sale in favor of his wife, Adriana Marquez, executed by Pia Ernacio, describing the land as having an area of 7,921 square meters; (2) succes...
Case Digest (G.R. No. L-45159)
Facts:
Background of the Case
- The case involves an action to quiet title filed by petitioner Jose Hermo against respondents Andres Floresca and Isidro Fulgueras in the Court of First Instance of Sorsogon.
- The dispute centered on a parcel of land between their respective holdings, with both parties claiming superior rights over the area.
Relocation Survey
- A court-appointed commissioner conducted a relocation survey, revealing that the disputed area measured 11,122 square meters, significantly larger than the parties' initial estimate of 3,500 square meters.
- Hermo sought and was granted leave to amend his complaint to reflect the correct area, without objection from the respondents.
Hermo's Claims
- Hermo based his claim on:
- A Deed of Sale executed in favor of his wife, Adriana Marquez, by Pia Ernacio, covering 7,921 square meters.
- Successive tax declarations.
- A Deed of Confirmation of Ownership dated July 17, 1967, purportedly executed by respondent Andres Floresca.
Respondents' Claims
- Respondents Floresca and Fulgueras based their claim on:
- A Deed of Absolute Sale executed by Benedicto Esperida on June 30, 1943, in favor of Andres Floresca, covering 17,479 square meters.
- A Deed of Absolute Sale dated May 23, 1966, by which Floresca conveyed the land to Fulgueras, described as 20,000 square meters.
- Successive tax declarations in the names of Floresca and Fulgueras, describing the land as 20,000 square meters.
Trial Court Decision
- The Lower Court ruled in favor of Hermo, emphasizing his continuous possession of the land since 1922 and declaring him the owner by acquisitive prescription under Act 190 and the Civil Code of 1889.
Court of Appeals Decision
- The Court of Appeals reversed the Trial Court's decision, finding the respondents' documentary evidence more credible and declaring Fulgueras the lawful owner by prescription.
Issue:
- (Unlock)
Ruling:
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Ratio:
Finality of Factual Findings by the Court of Appeals:
- The Supreme Court reiterated the well-established rule that factual findings of the Court of Appeals are final and conclusive, absent any serious and important reason to overturn them.
- The Court of Appeals is primarily tasked with reviewing and correcting factual errors of the Trial Court, and its findings are entitled to great respect.
Credibility of Evidence:
- The Court of Appeals found the respondents' documentary evidence more credible and consistent with the actual measurements of the land.
- Hermo's evidence, particularly the testimony of his witnesses, was deemed vague, uncertain, and not based on direct personal knowledge.
No Reason for Second Review:
- The Supreme Court refused to undertake a second review of the Trial Court's findings or the Court of Appeals' review of those findings, as no compelling reason was presented to justify such action.
Conclusion:
- The Supreme Court upheld the Court of Appeals' decision, affirming Fulgueras as the lawful owner of the disputed land and dismissing Hermo's petition. Costs were imposed on Hermo.