G.R. No. 97619 - Spouses Pilapil vs. Court of Appeals

The petitioners, Socrates Pilapil and Rosario Pilapil (collectively “Pilapils”), are the registered owners of a 6,598-square meter parcel of land situated in Sitio Bahak, Barangay Poblacion, Liloan, Cebu, as evidenced by Tax Declaration No. 15067 covering what were formerly Lot Nos. 320 and 323.
The private respondents, the Colomidas, residents of Mandaue City, acquired from a third party (Emeteria vda. de Ceniza and the heirs of Leoncio Ceniza) a parcel of land in the same area, originally described by a tax declaration (No. 19764), later confirmed by Free Patent No. (VII-1)-15448 and Certificate of Title No. P-20588.
The controversy centers on the existence and exact location of a camino vecinal (a barrio road), claimed to be present in Sitio Bahak. While the Colomidas assert that the road traverses into the property of the Pilapils, the latter contend that the road merely runs along the side of their property.

In July 1981, following a dispute on the improvement and use of the road—where the Colomidas alleged harassment and threats by the Pilapils while attempting to improve the camino vecinal—the Colomidas filed a petition for injunction and damages before the Regional Trial Court (RTC) of Cebu, Branch 17.
The Pilapils, in response, filed an answer denying the existence of the road on their property and subsequently instituted an action for damages in the Municipal Circuit Trial Court.
The RTC rendered a decision on 8 February 1988 in favor of the Colomidas, awarding them damages and injunction relief against the Pilapils.
The Court of Appeals affirmed the RTC decision on 26 October 1990, a resolution that the Pilapils later sought to reconsider.

Resolution No. 106 of the Municipal Council of Liloan (dated 18 August 1973) authorizing the local residents to repair and improve a camino vecinal.
Testimonies of local residents—Sesenando Longakit and Florentino Pepito—who attested that the camino vecinal, historically in use by the community, traverses the Pilapils’ property.
A sketch prepared by Longakit, which delineated the passage of the road across the disputed land.

Testimonies from witnesses such as Ramon Sungahid, Engineer Epifanio Jordan (Municipal Planning and Development Coordinator), and Socrates Pilapil, asserting that the camino vecinal only borders their property.
Documentary evidence including tax declarations and a zoning map (prepared by Engineer Jordan) that allegedly showed that the camino vecinal is proposed to run along the side and not across their land.

The evidentiary record was thus marked by conflicting accounts regarding the exact location and extent of the camino vecinal, with emphasis on both oral testimony and documentary exhibits.

Central to resolving the dispute was the approval by the Sangguniang Bayan (Municipal Council) of Liloan of an Urban Land Use Plan (or zoning map), which established the location of the camino vecinal.
Engineer Epifanio Jordan testified that the approved plan confirmed the road’s position as passing along the side of the Pilapils’ property, although the Colomidas argued that the evidence supports its traversal through that property.
The official municipal act, evidenced by the zoning map and corroborated by Engineer Jordan’s testimony (despite minor inconsistencies concerning the orders leading to its preparation), was pivotal in determining the roadway’s location.

After the RTC and the Court of Appeals rendered decisions favoring the Colomidas, the Pilapils filed a petition for review under Rule 45 of the Rules of Court.
In their petition, the Pilapils alleged errors in the factual findings and criticism over the weight accorded to the evidence, particularly arguing that the trial courts failed to properly appreciate:

The exchange of motions and manifestations (including the Colomidas’ request for dismissal on the ground of conclusiveness of findings) further complicated the procedural landscape before the Supreme Court granted the petition for review.

Whether a camino vecinal exists in Sitio Bahak, Barangay Poblacion, Liloan, Cebu, as a matter of fact and law.

The parties agree on the existence of a camino vecinal, but disagree on its precise location.

Whether the existing camino vecinal traverses the property of the Pilapils or merely runs alongside their land.
The proper application and weight to be given to municipal acts—specifically, the approval of the Urban Land Use Plan or zoning map by the Sangguniang Bayan—in determining the course of the public road.
The extent to which conflicting testimonial evidence and documentary exhibits should influence the adjudication of the location of the camino vecinal in light of established municipal authority.