G.R. No. 76005 - People vs. Exala

Petitioners: Spouses Kawasa Magalang and Mona Wahab, claiming ownership of a 10-hectare property (Lot 1064, Pls-397-D) in Salabaca, Ampatuan, Cotabato (now Daladap, Esperanza, Sultan Kudarat).
Respondents: Spouses Lucibar Heretape and Rosalina Funa; Roberto Landero; Spouses Nestor Heretape and Rosa Rogador; and Engr. Eusebio F. Fortinez.
Nature of Case: Recovery of possession and ownership and/or declaration of nullity of acquisition of property over Lot 1064 and its subdivided portions.

Petitioners claimed ownership through inheritance, planting coconut, banana, bamboo trees, and palay on the land, and payment of taxes.
On February 4, 1969, a memorandum of agreement was executed between Kawasa Magalang and Lucibar Heretape allowing the latter to occupy and cultivate 2.5 hectares as a mortgage for P1,310.00.
In the early 1970s, conflict caused Kawasa Magalang and family to evacuate. Respondents allegedly usurped the entire 10-hectare lot, caused subdivision into Lot 1064-A, Lot 2238-A, and Lot 2238-B, and obtained free patent titles through allegedly forged documents and fraud.
Respondents contended that Pedro Deansin was the rightful owner, presenting Bureau of Lands documents, deeds of transfer of rights, and purchased half of the lot from Deansin.
Respondents claimed they obtained original certificates of title (OCT) for the subdivided lots in their names.

Petitioners filed a complaint for recovery of possession and ownership and/or declaration of nullity of acquisition on May 7, 1999.
Petitioners presented testimonies affirming ownership and possession, including payment of taxes and original possession. Documentary evidence included tax receipts, memorandum of agreement, tax declaration, and a Barangay certificate for filing of action.
Respondents presented testimonies and documentary evidence including various deeds of sale and transfer, dated decisions and orders from the Bureau of Lands, applications for free patent titles, original certificates of title registered in their favor, and related investigative reports.
Respondents’ documentary evidence was largely comprised of photocopies identified by the custodian of records of CENRO-Tacurong, but the trial court declared these inadmissible for being copies rather than originals.

By judgment dated October 3, 2003, the trial court ruled in favor of the petitioners.
It ordered respondents to vacate the subdivided lots, declared respondents’ deeds and OCTs null and void, directed the surrender of certificates of title, and reconveyance of property in favor of petitioners.
The trial court favored petitioners’ testimonial evidence and rejected respondents’ documentary evidence due to lack of originals.

Respondents Spouses Lucibar Heretape and Rosalina Funa, Spouses Nestor Heretape and Rosa Rogador, and Roberto Landero separately appealed.
Court of Appeals ruled in favor of respondents on December 30, 2010, reversing the trial court and dismissing the complaint.
It ruled that petitioners failed to prove ownership by clear and convincing evidence and failed to prove fraud in respondents’ acquisition of titles.
The Court emphasized the conclusive presumption of ownership from the original certificates of title in respondents’ favor.
The Court denied petitioners’ motion for reconsideration on October 6, 2011.

Petitioners filed a Petition for Review on Certiorari invoking the Supreme Court's appellate jurisdiction.
They reiterated their claim of ownership by prescription and alleged fraudulent acquisition of titles by respondents.
Respondents maintained lawful acquisition of titles supported by original documents and long-standing possession.

Whether petitioners are entitled to reconveyance of the entire Lot 1064 or the subdivided lots (Lot 2238-B, Lot 2238-A, and Lot 1064-A).
Whether petitioners sufficiently proved by clear and convincing evidence that respondents fraudulently acquired their titles.
Whether petitioners established ownership by acquisitive prescription over the disputed property.
Whether the trial court erred in rejecting respondents’ documentary evidence for being photocopies.