Facts:

The case at hand involves petitioners St. Peter Memorial Park, Inc. (now Himlayang Filipino, Inc.) and Banco Filipino Savings & Mortgage Bank, who are contesting the ownership of Lot No. 719 of the Piedad Estate against respondents Regino Cleofas and Lucia De La Cruz. The origins of the dispute trace back to the alleged sale of the lot to Antonio Cleofas by the government in July 1929, with documentation marking this transaction marked as Exhibit "A." Subsequently, the legality of this claim was challenged, especially concerning the purported assignment of the land from Antonio Cleofas to Aniceto Martin.

After the trial court denied petitioners' initial request for a new trial to present what they claimed were newly discovered evidentiary documents, the Supreme Court allowed for a new trial based on precedent from an earlier case involving the same parties (St. Peter Memorial Park vs. Campos, Jr., 63 SCRA 180). In the new trial, the petitioners presented evide

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Facts:

Background of the Case

• Petitioners: St. Peter Memorial Park, Inc. (now Himlayang Pilipino, Inc.) and Banco Filipino Savings & Mortgage Bank filed separate motions for reconsideration of the July 30, 1979 decision.
• These motions for reconsideration were delayed due to incidents, including the inability of the First Division to reach a consensus, which eventually referred the case to the Court en banc in consulta pursuant to the Resolution of October 28, 1981.

Supplemental Motion for Reconsideration and New Trial Prayer

• During the pendency of the motions for reconsideration, petitioners filed a Supplemental Motion for Reconsideration on December 14, 1979.
• They alternatively prayed:
• That their motions for reconsideration be reviewed in light of additional documentary evidence attached for judicial notice; or
• That, if procedural or technical grounds precluded the above, the case be remanded to the trial court for a new trial to allow the presentation of newly discovered evidence.
• The request for a new trial was grounded on earlier Supreme Court precedent (St. Peter Memorial Park vs. Campos, Jr., 63 SCRA 180) which permitted a new trial despite a previous denial by the trial court.

Core Evidence in Dispute

• Central to the petitioners’ claim was the contention regarding Lot No. 719 of the Piedad Estate. They argued that:
• The evidence showing the sale of Lot No. 719 used by the respondents—specifically, Sheet 15 of OCT No. 614 marked as Exhibit “A”—actually pertained to Lot No. 640, not Lot No. 719.
• The petitioners supported their claim with a purported Deed of Assignment of Certificate of Sale No. 923 (Exhibit “1”), allegedly executed by Antonio Cleofas (and also by Ruperto Cleofas), assigning the rights over Lot No. 719 to Aniceto Martin, their predecessor-in-interest.
• The trial court, however, found that:
• Although Antonio Cleofas was awarded Lot No. 719 under Sale Certificate No. 923, the Deed of Assignment (Exhibit “1”) was spurious.
• Reasons for suspecting spuriousness included:
• The poor custody of the documents—Exhibit “1” and the accompanying Deed of Conveyance (Exhibit “2”) were not in the custody of the proper registrar but in the petitioners’ possession.

ii. The deed of assignment bore only a thumbmark of Antonio Cleofas, despite available evidence of his competence to sign.

Discovery of New Evidence

• Petitioners continued their inquiry and discovered additional documentary evidence during the pendency of their motions:
• Inquiries were conducted in the Bureau of Lands, Registries of Deeds for Pasig, Quezon City, and Caloocan City.
• Evidence found included certified photocopies of:
• Deed of Conveyance (Exhibit “2”) and TCT No. 21893 (Exhibit “3”) as evidence of the sale to Trino Narciso and Aniceto Martin.

ii. Archival records (such as page 10 of OCT No. 543 pertaining to the Tala Estate) that provided entries evidencing the sale transaction for Lot No. 719. iii. Notarial documents and entries corroborating the authenticity of the disputed instruments, including the notary’s copy of Notarial Document No. 828 and corresponding entries in the notarial register.

Respondents’ Opposition

• Respondents contended that:
• The new evidence was not “newly discovered” since with due diligence it should have been available during the trial.
• The evidence did not alter the finding regarding the custody and authenticity of Exhibits “1” and “2”.
• However, the Court found that:
• The age of the documents (executed over sixty years ago) and their misfiling in government records rendered them undiscoverable with reasonable diligence during the trial.
• The procedural requirements for the new trial under the Rules of Court (particularly Sections 4 of Rule 37 and Section 1, Rule 53 in relation to Section 1, Rule 56) were satisfied.

Issue:

The Admissibility and Impact of New Evidence

• Whether the additional documentary evidence discovered by the petitioners qualifies as “newly discovered evidence” warranting a new trial.
• Whether the evidence is sufficient to rebut the trial court’s prior adverse finding regarding the authenticity of the deed of assignment (Exhibit “1”) and the deed of conveyance (Exhibit “2”).

Validity and Proper Interpretation of the Land Title Documents

• Whether the misfiled entries in the Registry of Deeds (mistakenly registering documents in OCT No. 543 rather than OCT No. 614) have any bearing on the authenticity of the petitioners’ documents.
• Whether the evidence shows conclusively that Lot No. 719 was properly assigned and conveyed to petitioners’ predecessor, Aniceto Martin, despite the trial court’s original determination.

Procedural and Evidentiary Considerations

• Whether the petitioners’ failure to present the evidence during the original trial, due to its unavailability and misfiling by government offices, justifies a new trial.
• Whether the respondents’ reliance on the technical custody of documents is sufficient to outweigh the newly discovered evidence.

Ruling:

• (Subscriber-Only)

Ratio:

• (Subscriber-Only)

Doctrine:

• (Subscriber-Only)