Title
Marquez vs. Espejo
Case
G.R. No. 168387
Decision Date
Aug 25, 2010
Dispute over agricultural land ownership: respondents claimed repurchase of Murong property, but SC ruled Deed of Sale covered Lantap, VLTs/CLOAs covered Murong.

Case Digest (G.R. No. 168387)
Expanded Legal Reasoning Model

Facts:

  • Parties and Properties
    • Respondents Espejos were original registered owners of two parcels of agricultural land, each two hectares, located in Barangay Lantap and Barangay Murong, Bagabag, Nueva Vizcaya (the Lantap property and the Murong property).
    • The Lantap property was tenanted by respondent Nemi Fernandez (Nemi), husband of respondent Elenita Espejo; petitioners Salun-at Marquez (Marquez) and Nestor Dela Cruz (Dela Cruz) tenanted the Murong property.
    • Respondents mortgaged both properties to Rural Bank of Bayombong, Inc. (RBBI) to secure loans; after default, RBBI foreclosed and acquired titles consolidated under TCT Nos. T-62096 (Murong) and T-62836 (Lantap).
  • Transactions and Titles
    • On February 26, 1985, respondents bought back one lot from RBBI by a Deed of Sale referring to TCT No. T-62096 (Murong property) but did not take possession or assert ownership over the Murong property.
    • On June 20, 1990, RBBI executed Deeds of Voluntary Land Transfer (VLTs) in favor of petitioners relating to lands described as situated in Barangay Murong but covered by TCT No. T-62836 (Lantap property).
    • Petitioners completed payments; Certificates of Land Ownership Awards (CLOAs) issued in their favor on September 5, 1991, described the lands in Barangay Murong.
  • Dispute and Proceedings
    • In February 1997, respondents filed complaint for cancellation of petitioners’ CLOAs alleging the Murong property, occupied by petitioners, was bought back by them.
    • Petitioners argued they bought the Murong property as bona fide tenant-farmers and that respondents repurchased the Lantap property. RBBI supported petitioners’ position.
    • OIC-RARAD gave weight to TCT numbers; canceled petitioners’ CLOAs for Murong property (erroneously awarding Lantap property to petitioners) based on the documents’ literal terms and typographical error in location description.
    • DARAB reversed RARAD; upheld petitioners’ CLOAs as bona fide beneficiaries and ruled respondents repurchased the Lantap property, ordering respondents to formalize lease with Nemi for Lantap property.
    • Court of Appeals reversed DARAB; ruled that literal terms (title numbers) in the Deed of Sale and VLTs control, awarding Murong property to respondents and Lantap property to petitioners, and canceled petitioners’ CLOAs for Lantap property disqualification.
    • RBBI separately appealed but the Supreme Court dismissed their petition for lack of merit.
    • Petitioners filed the present petition assailing the appellate ruling on the proper application of the Best Evidence Rule and determination of respective subject properties.

Issues:

  • What is the effect of the final judgment dismissing RBBI’s Petition for Review on Certiorari attacking the same CA Decision?
  • Whether the Court of Appeals erred in applying the Best Evidence Rule to determine the subject properties covered by the parties’ contracts?
  • What are the correct subject properties of the Deed of Sale and Deeds of Voluntary Land Transfer?

Ruling:

  • (Subscriber-Only)

Ratio:

  • (Subscriber-Only)

Doctrine:

  • (Subscriber-Only)

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