G.R. No. 127382 - Serina vs. Caballero

On August 11, 1982, Dr. Jesus SeriAa and his wife, Enriqueta SeriAa, filed a complaint for quieting of title, recovery of possession, and damages, with a prayer for a writ of preliminary mandatory injunction against respondents Victor Caballero and his tenants (Teodoro Donela and Oliver Donela).
After Dr. Jesus SeriAa’s death on August 6, 1983, his children—Jesus, Jr., Antonio, Violeta, Reynaldo, and Emmanuel—substituted as the petitioners.

The petitioners claimed that they were the absolute owners, having been in actual and constructive possession of a specific parcel of land for 35 years.
The land was described as Lot No. 3533-A, Cad-237, Cagayan Cadastre Tax Declaration No. 02161, located in Mantadiao, Opol, Misamis Oriental, with an area of 2.5 hectares.
Boundaries as alleged in the complaint were:

The petitioners presented a Deed of Sale dated August 23, 1947 showing the purchase of 5 hectares of ricefield from Lucia Vda. de Marbella, who had acquired the land from Ramon Neri.
Tax Declaration No. 4029 was issued in the name of Dr. SeriAa for the subject property, and the petitioners asserted they had been regularly paying taxes from 1947 to the present.

Respondent Victor Caballero alleged being the lawful owner and claimed actual, physical possession since time immemorial.
Evidence was presented that the disputed land was originally owned by his grandfather, Eustaquio Caballero, as shown by Tax Declaration No. 2442, which in turn revealed that the land was divided among Eustaquio’s children upon his death in 1944.
Testimonies from Emiliana Ibarat and Gliceria Legaspi established different boundary descriptions and lot divisions, confirming the division and sale of portions of Lot A.

The petitioners’ complaint described the property with certain boundaries and a 2.5-hectare area, contrasting the Deed of Sale’s description (boundaries and a 5-hectare area).
There was a noted discrepancy between the location stated in the complaint (Mantadiao, Opol, Misamis Oriental) and that in the Deed of Sale (Puntakon, Igpit, Cagayan de Oro).
Differences in the boundary owners as indicated in the respective tax declarations (Tax Declaration No. 2442 vs. No. 4029) further complicated the identification of the land.

The trial court (RTC of Misamis Oriental, Branch 20, Cagayan de Oro City) rendered judgment on January 21, 1992, dismissing the complaint.
The RTC ruled that the petitioners failed to clearly establish the identity of the land, noting discrepancies in boundaries, area, and location between the complaint, the Deed of Sale, and the tax declarations.
Costs, including litigation expenses and attorney’s fees, were imposed on the petitioners.

Dissatisfied with the RTC judgment, the petitioners appealed to the Court of Appeals (CA), which affirmed the RTC ruling in toto.
A subsequent Motion for Reconsideration was filed by the petitioners on September 30, 1996, which the CA denied.
The petitioners then assailed two main errors: failure to establish the identity of the land and failure to appreciate a 35-year acquisitive prescription.

Whether the petitioners were able to clearly establish the identity of the land being claimed given the conflicting descriptions in the complaint, the Deed of Sale, and the tax declarations.
Whether the petitioners’ claim of acquisitive prescription is sustainable, particularly in view of the alleged 35-year possession and the discrepancies in the identity of the disputed property.