Case Digest (G.R. No. 174844)
Facts:
Petitioners Vevencia Echin Pabalan, et al. appealed the Court of Appeals' 22 May 2006 reversal of the Regional Trial Court, Branch 26, Southern Leyte's 20 August 1997 Decision in Civil Case No. R-263 involving a disputed parcel in Barrio/Barangay Estela, Liloan, Leyte. The chain of title shows Onofre Palapo sold to Placido Sy‑Cansoy on 31 December 1910, Placido sold to Antonia Bayon on 12 October 1912 (acknowledged 29 October 1934), Antonia filed an ejectment suit (Civil Case No. 298) resolved 17 December 1934, respondents (the heirs of Simeon A.B. Maamo, Sr.) sued in 1981 for recovery, the RTC in 1997 awarded ownership to defendants Palapo by prescription, and the CA in 2006 declared respondents owners and reversed the RTC.
Issues:
- Did the Court of Appeals err in reversing the RTC and declaring respondents the lawful owners despite petitioners' claim of adverse possession since 1906?
- Did the CA disregard Simeon Sr.'s alleged admission that respondents were not in possession from 1935 to 1981, thereby rendering the complaint barred by estoppel and laches?
- Did the CA err in declaring respondents owners by prescription under the Civil Code?
- Did the CA improperly rely on the judgment in Civil Case No. 298 as basis for respondents' possession?
- Did the CA err in finding that Simplecio's possession was by mere tolerance of respondents' predecessors?
Ruling:
The Supreme Court DENIED the petition for review and AFFIRMED the Court of Appeals' 22 May 2006 Decision. The Court held that the petition was largely factual and, where factual findings of the trial court and the CA diverged, the CA's findings were supported by the record and therefore binding.
Ratio:
The Court found that the CA correctly established that Antonia acquired the property on 12 October 1912, predating Simplecio's alleged 17 October 1934 entry, and that the deeds, tax declarations and the commissioner’s sketch consistently traced respondents' title to the 1910–1912 conveyances. The 17 December 1934 judgment in Civil Case No. 298 conclusively settled Antonias material possession, the writ of execution was returned served, and possession by mere tolerance or license cannot give rise to acquisitive prescription under Art. 444, Art. 1942, and Article 1119; estoppel and laches therefore did not prevail.
Doctrine:
- Under Rule 45, certiorari is confined to questions of law and will not ordinarily reexamine factual determinations.
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