G.R. No. 248932 - Province of Occidental Mindoro vs. Agusan Petroleum and Mineral Corporation

Juana Gutierrez owned a parcel of land later designated as Lot 4221 in Sto. Niño, Taysan, Batangas.
On January 4, 1961, she sold the lot to private respondent Buenaventura An for P850.00 through a "Kasulatan ng Bilihan ng Lupa."
The deed of sale stated an estimated area of 822.5 square meters and defined the boundaries as follows:

North: Taysan-Lobo-Sto. Niño-Pinagbayanan and Sto. Niño-Dagatan Road (intersection).
East: Sto. Niño-Pinagbayanan Road and the name "Juana Gutierrez."
South: Adjacent to the Sto. Niño School site.
West: Bound by the Sto. Niño-Dagatan Road.

Buenaventura An took physical possession of the lot by observing the defined boundaries rather than the stated area.

Lot 4215 (8,606 square meters) from the spouses Pascual Hornilla and Gliceria Ilao on June 30, 1964.
Another lot with an area of 11,000 square meters from Santiago Asi.

On October 18, 1972, he sold Lot 4221 to his nephew, Cipriano Ramirez, via another "Kasulatan ng Bilihan ng Lupa" for P2,500.00.

The document described Lot 4221 with the same area and most of the original boundaries except for the east boundary, which was changed from “Juana Gutierrez” to “Buenaventura An” to reflect the acquisition of adjacent Lot 4215.

Cipriano Ramirez occupied the property similarly by respecting the boundaries stated in his deed.
During the pendency of administrative proceedings (application for a new tax declaration), it was discovered that, per the Taysan Cadastral Mapping Survey conducted in 1974, the actual area of Lot 4221 was 2,200 square meters rather than the 822.5 square meters originally stated.
On March 12, 1979, Cipriano Ramirez sold the lot to petitioner Miguel Semira for P20,000.00.

On March 17, 1979, petitioner Miguel Semira entered Lot 4221 – the premises previously occupied by Ramirez – and began constructing a new rice-mill.
On April 18, 1979, private respondent filed a complaint for forcible entry in the Municipal Circuit Trial Court of Taysan-Lobo.

The respondent asserted that only 822.5 square meters comprised Lot 4221, claiming that the additional 1,377 square meters forcibly occupied by petitioner was part of Lot 4215, which he acquired earlier.

Petitioner admitted to entering the disputed portion but denied any unlawful entry.
In his answer, petitioner invoked the 1979 deed of sale (from Cipriano Ramirez) as the basis of his ownership over Lot 4221.

The Municipal Circuit Trial Court initially dismissed the case on the ground that the issue of prior physical possession could not be resolved without first determining ownership.
After a motion and in view of the enactment of B.P. Blg. 129 (effective August 14, 1981), which allowed forcible entry cases to address ownership issues, the trial court modified its resolution.

It adjudged petitioner the rightful and lawful owner and possessor of the disputed area, thus preventing his ejection.

The Regional Trial Court reversed the Municipal Circuit Trial Court’s decision, ruling that prior physical possession alone (with petitioner’s possession commencing on March 12, 1979, and respondent’s possession since 1964) was sufficient to resolve the dispute.

The RTC held that, since petitioner did not specifically deny the allegation of forcible deprivation, the claim was deemed admitted.

The Court of Appeals affirmed the RTC ruling, thereby upholding the respondent’s claim.
Petitioner then appealed, arguing:

That there was no clear and indubitable proof of respondent’s prior physical possession.
That the issue of ownership is so inherently linked to possession that it must be resolved before deciding on mere physical occupancy.

Whether the issue of forcible entry and prior physical possession can be resolved independent of the determination of ownership.
Whether the 1979 deed of sale, which defined the boundaries of Lot 4221, effectively conveyed the entire lot as delimited (i.e., 2,200 square meters) despite the originally stated area being only 822.5 square meters.
Whether the contractual description (boundaries) in a lump sum sale overrides discrepancies in the stated area of land.
Whether private respondent's claim of prior possession (commencing in 1964) suffices to establish a right to exclude petitioner despite the contested boundaries and ownership issues.
Whether the doctrine embodied in Art. 1542 of the Civil Code applies, dictating that the actual area of a lot is determined by its boundaries for lump sum land sales.