G.R. No. 139603 - Quinao vs. People

On February 2, 1993, an Information was filed before the Regional Trial Court (RTC) of Laoang, Northern Samar, accusing Conchita Quinao and Salvador Cases of usurping a real property owned by Francisco F. Del Monte, converting 12,000 coconuts into copra and selling them for ₱14,580.00.
At arraignment, both accused pleaded not guilty. Trial ensued, witnesses testified, and evidence was submitted.
On April 9, 1995, co-accused Salvador Cases died. The RTC proceeded against Conchita Quinao alone.
On January 14, 1999, the RTC found both accused guilty of usurpation under Article 312, Revised Penal Code, sentenced them to pay a fine of ₱174,960.00, and enjoined them from entering the property.
Conchita Quinao appealed to the Court of Appeals (CA) in CA-G.R. CR No. 19412. The CA affirmed the RTC decision on January 14, 1999, and denied her motion for reconsideration on June 30, 1999.
On July 14, 2000, Conchita Quinao filed a petition for review on certiorari with the Supreme Court.

Tax Declaration No. 1202 in the name of Petre Del Monte (predecessor-in-interest) canceled Tax Declaration No. 18612.
Decision in Civil Case No. 3561 adjudicated the same land to Del Monte’s predecessors.

Tax Declaration No. 1195 in the name of Lorenzo Cases, dated January 25, 1993, covering 6 ha 34 ca 28 a.
Claim of inheritance from their grandfather, payment of realty taxes, actual possession.

On February 2, 1993, at around 9 a.m., accused Quinao and Cases, with relatives, forcibly entered the land, used violence and intimidation, gathered coconuts and converted them into copra.
They drove out the witness, threatened him, and compelled him to seek police assistance.

Established by sketch that the area claimed by the accused encroached on Del Monte’s land as awarded in Civil Case No. 3561.

RTC judgment: adopted the commissioner’s report; found all elements of usurpation proven beyond reasonable doubt.

Whether an elderly woman petitioner could be held liable for usurpation on the basis of alleged conspiracy founded on speculation.
Whether the force and intimidation used by the accused after entry sufficed to establish the crime of usurpation of real property.
Whether one claiming ownership of the land in question can be held liable for usurpation of her own property.