Facts:

• Jose Rubiato is the petitioner against the heirs of his deceased brother, Jovito Rubiato.
• The case originated from the allocation of Farm Lot No. 639, Pls-246-D in Koronadal, South Cotabato, by the National Resettlement and Rehabilitation Administration (NARRA) to spouses Anastacio and Catalina Dignadice.
• On June 12, 1950, Catalina sold the farm lot to Jose Rubiato.
• On January 22, 1991, Jose filed a complaint against Jovito's heirs, claiming that Jovito fraudulently obtained a title to the property using a forged resignation letter from Jose.
• The respondents denied the allegations, asserting that the title was lawfully obtained after Jose voluntarily transferred possession and cultivation of the lot to Jovito.
• The Regional Trial Court (RTC) dismissed Jose's complaint on September 26, 1994, stating that the lot was still public land at the time of the alleged forgery and that Jose had not applied for titling, lacking vested rights.
• The RTC also noted Jose's thirty-six-year delay in asserting his claim, which constituted laches.
• Jose appealed to the Court of Appeals, which affirmed the RTC's decision on July 23, 1998.
• After his motion for reconsideration was denied on January 13, 1999, Jose filed a petition for review on certiorari.

Issue:

• (Unlock)

Ruling:

• The Supreme Court denied the petition for review, affirming the Court of Appeals' decision dated July 23, 1998, which upheld the R...(Unlock)

Ratio:

• The Supreme Court stated that factual issues are typically outside its jurisdiction in a petition for review, as it does not re-evaluate evidence from lower courts.
• The Court emphasized that the factual findings of the trial court, confirmed by the Court of Appeals, are binding and conclusive.
• The RTC determined that Jose h...continue reading