G.R. No. 11045 - Tolentino vs. Paraiso

Ildefonso Tolentino, the plaintiff, claimed ownership of a parcel of land by virtue of his inheritance from his late father, Simeon Tolentino, formalized in an extrajudicial partition dated July 15, 1909 (Exhibit A).
The land in dispute was situated in the sitio of Macabaclay, in the town of Bongabong, Nueva Ecija, and had historical cultivation and productivity, producing palay at an annual rate mentioned in the records.

Miguela Tolentino, daughter of Canute Tolentino and niece of Ildefonso, inherited a parcel of rice land from her father as her legitimate portion, which was described in his will executed on May 30, 1894 (Exhibit B).
On April 21, 1911, Miguela Tolentino transferred, by deed of absolute sale, a parcel of land to Tomas Paraiso and his wife Isidra Gonzalez for the sum of P200.
The deed of sale, however, contained conflicting descriptions: while it erroneously described the land as having an area of 12 hectares, the vendor testified that she only sold a parcel measuring 6 cavanes of seed (approximately 6 hectares, 3 ares, and 72 centares), which was the only property she actually inherited.

Ildefonso Tolentino asserted that the land he inherited and possessed from his father—on which he had long worked and from which significant agricultural produce was derived—had been unlawfully encroached upon by the defendant.
It was further claimed that the defendant had usurped an adjacent parcel of one and one-half cavanes, which rightfully belonged to the plaintiff, as it was erroneously included in the area described in the deed of sale.

Tomas Paraiso insisted that he had acquired the land from Miguela Tolentino through a valid sale transaction.
The defendant argued that the document, as presented, substantiated his claim to a larger tract of land (12 hectares), thereby legitimizing his possession.

Testimonies from adjacent land owners (Jose Ybai and Eusebio Bartolome) established that during the transfer, the boundaries were measured and confirmed that the plaintiff’s land was not part of the parcel sold by the vendor.
Documentary evidence (Exhibit A and Exhibit B) clearly indicated the separate origins and dimensions of the parties’ respective parcels of land.

The action for recovery of the land was originally filed by Ildefonso Tolentino in the Court of First Instance of Nueva Ecija on May 28, 1913.
After trial, a judgment on October 27, 1914, declared the sale by Miguela Tolentino to Tomas Paraiso null and void. The judgment ordered that the land be restored to the plaintiff with an indemnity calculated from the lost produce.
The defendant, dissatisfied with the decision, filed a bill of exceptions and appeals, contending that the lower court had erred in its findings and in granting relief to the plaintiff.

Whether Ildefonso Tolentino, through inheritance and an extrajudicial partition, was the true owner of the disputed parcel of land.
Whether the alleged transfer of land by Miguela Tolentino to Tomas Paraiso was valid and whether it extended over the parcel allegedly usurped by the defendant.

Whether the deed of sale executed by Miguela Tolentino, which described the land as 12 hectares instead of the actual 6 cavanes she possessed, carries any legal effect over the adjacent land claimed by the plaintiff.
Whether the lack of capacity (inability to read or understand Spanish) of the vendor affected the validity of the transaction.

Whether Tomas Paraiso’s actions in utilizing a deceptive deed of sale amounted to a fraudulent act intended to usurp the plaintiff’s property.
The sufficiency of evidence indicating that the defendant held the land in bad faith, thereby justifying the recovery action by the plaintiff.