G.R. No. 172611 - Spouses Valenzuela vs. Spouses Mano Jr.

Petitioner Federico Valenzuela is the son and heir of Andres Valenzuela, who originally owned a 938-square meter parcel of land in Dampol 1st, Pulilan, Bulacan, as evidenced by Declaration of Real Property No. 7187.
Other petitioners include Luz Buena-Valenzuela, while respondents are Jose Mano, Jr. and Rosanna Reyes-Mano.

Andres Valenzuela's property, measuring approximately 938 square meters, was passed on to Federico upon Andres’ death on October 10, 1959.
On August 5, 1980, Andres’ heirs executed a document (Pagmamana sa Labas ng Hukuman at Pagpaparaya o Pagkakaloob) waiving their rights in favor of Federico.

On February 7, 1991, Feliciano Geronimo executed a Deed of Conditional Sale with respondent Jose Mano, Jr. for a parcel described as measuring 2,056 square meters in Dampol 1st, Pulilan, Bulacan.
A corresponding Deed of Sale was executed in March 1991. Shortly thereafter, on March 4, 1992, Jose applied for a Free Patent, and on April 10, 1992, Original Certificate of Title (OCT No. P-351) was issued in his name; however, the area indicated was 2,739 square meters—a discrepancy from the area sold.

Subsequent developments involved the issuance of separate Transfer Certificates of Title: TCT No. T-112865 in the name of Roberto S. Balingcongan (covering 2,292 square meters) and TCT No. T-112864 in the name of Jose (covering 447 square meters).
The 447-square meter area became the subject of dispute; while Jose claimed it as part of the purchased property, Federico asserted that it was part of the land inherited from his father.
Tensions escalated when Federico, having transferred his residence to Malabon and entrusting the property’s care to his nephew Vicente Joson, encountered obstruction during perimeter fence construction—Jose claimed exclusive rights over that portion.

Unable to settle the dispute amicably, the petitioners filed a Complaint for Annulment of Title and/or Reconveyance, Damages with the Regional Trial Court (RTC) of Malolos, Bulacan.
At pre-trial and during trial, evidence was presented regarding ownership, boundaries, and the discrepancies in area measurements.
On March 10, 2004, the RTC ruled in favor of Federico by:

Ordering the return of the disputed 447 square meters to Federico;
Directing the removal of a concrete fence erected by respondents;
Mandating the payment of moral damages, exemplary damages, and attorney’s fees; and
Ordering the cancellation of TCT No. T-112864.

Respondents appealed the RTC decision, and on January 16, 2006, the Court of Appeals (CA) reversed the RTC ruling, subsequently denying a motion for reconsideration on May 3, 2006.

Whether the Court of Appeals gravely abused its discretion by holding that the petitioners failed to prove ownership of the disputed 447-square meter portion despite evidence evidencing Federico’s inherited rights and possession.
Whether the CA erred in dismissing the fraud allegations against Jose Mano, Jr., particularly regarding the misrepresentation in the application for a Free Patent and the inclusion of an erroneous area in the title, thereby denying the petitioners a remedy against fraudulent acquisition.