A.C. No. 6492 - Zoreta vs. Simpliciano

The plaintiff-appellant, Mamerto Iriola, initiated a suit for the declaration of ownership and the reconveyance of a parcel of land situated in the Barrio of Bagong Sirang, Pili, Camarines Sur.
The complaint alleged that the plaintiff, along with his predecessors-in-interest, possessed the land continuously, peacefully, openly, and adversely for more than ten years.
The disputed parcel is described as having an area of 2 has., 11 ares, and 50 centares and is defined by specific boundaries noted in the complaint.
The complaint further stated that on or about February 25, 1949, the defendant-appellee, Silverio Felices, secured a homestead patent (Certificate of Title No. 104) for an 8-hectare parcel of land, which encompassed the smaller parcel claimed by the plaintiff.
The plaintiff charged that the defendant fraudulently included the disputed portion in his homestead patent to undermine the plaintiff’s claim and that the correct title should be in the plaintiff’s name, warranting a reconveyance.

The plaintiff filed his complaint on June 2, 1954, asserting both ownership and adverse possession of the disputed land, and praying for a judgment declaring him as the rightful owner and for an order directing the defendant to execute a deed of reconveyance.
On June 23, 1954, the defendant filed his answer and affirmative defenses, which included a counterclaim.
In his answer, the defendant contended:

He was the registered owner of the entire property, with the disputed land being an integral part of his title.
Until February 24, 1949, he retained exclusive possession of the property, and on that date, he conditionally sold a portion measuring 4 1/4 hectares to the plaintiff.
The plaintiff, however, wrongfully took possession of an area exceeding the portion sold, thus depriving the defendant of possession of over 3 hectares.

The defendant further raised the affirmative defense of estoppel, claiming that the plaintiff, by his own actions and admissions, could not now assert ownership of the disputed portion that clearly formed part of the larger titled property.

Central to the dispute was a "Deed of Conditional Sale" purportedly executed on February 24, 1949, wherein the defendant sold a 4 1/4-hectare portion of the property to the plaintiff.
The deed contained key statements:

It described the parcel sold by clearly stating its boundaries – being bounded on the north by the defendant’s property, on the east by the Himaano River, on the south by the property of the heirs of Felipe Felices, and on the west by the Lagundi Creek.
It noted that the sale was of a parcel which was an integral part of the larger land covered by Homestead Patent No. V2117, which was declared and assessed for taxation in the name of Silverio Felices.
It included an assertion that the defendant had been in continuous and peaceful possession of the said parcel since 1921.

The plaintiff did not specifically deny the genuineness or the due execution of the deed under oath, which rendered its recitals as admitted evidence, though the interpretation of its scope was subject to dispute.

On June 20, 1955, the defendant moved to dismiss the complaint on grounds of lack of cause of action and estoppel, relying on the deed and his counterclaim.
The plaintiff objected, and subsequent pleadings including an "Answer to Reply" were filed which clarified that while he admitted possession of the certificate of title on February 24, 1949, he denied having actual knowledge that the disputed land was covered by the title.
The lower court denied the defendant’s motion to dismiss both in 1955 and again when a similar motion was refiled on February 11, 1957.
During the initial trial, the defendant sought to exclude the testimony of the plaintiff’s first witness on the basis that the plaintiff was estopped from proving ownership over the portion of land in dispute.
Ultimately, an order was issued wherein the plaintiff was held estopped from presenting evidence of ownership of the contested portion, prompting the plaintiff’s appeal to the Supreme Court.

The fundamental issue arose from whether the plaintiff, through the deed of conditional sale and his replies in the pleadings, had inadvertently admitted that the disputed portion was part of the larger homestead property registered in the defendant’s name.
The contention focused on whether the statements in the deed and in the plaintiff’s rejoinder were sufficiently precise and unequivocal to invoke an estoppel against him from claiming a separate title to the disputed land.

Whether the conditional sale deed, along with the plaintiff’s admissions contained therein or in subsequent pleadings, constitutes a clear, distinct, and precise assertion establishing an estoppel against the plaintiff in claiming ownership over the disputed land.
Whether the boundaries described in the deed of sale are confined to the 4 1/4-hectare portion or extend to encompass the entire land covered by Homestead Patent No. V2117, thereby affecting the plaintiff’s claim.
Whether the plaintiff’s conduct and his failure to repudiate the deed under oath effectively led to an estoppel barring his claim to the disputed three (3) hectares which he contends was wrongfully incorporated into the defendant’s homestead patent.
Whether the legal requirements for estoppel by deed—namely, the necessity of a specific and unequivocal acknowledgment—have been met in this case.
Whether the proper application of estoppel in this context precludes the plaintiff from asserting equitable title based on his adverse possession and the factual circumstances surrounding the conditional sale.