Case Summary (G.R. No. 146586)
Applicable Law
The relevant legal framework for this case includes provisions from the Civil Code of the Philippines concerning donations, and the Revised Rules of Evidence, especially regarding the admissibility of secondary evidence.
Background of the Case
Respondents filed a complaint for Recovery of Possession against DECS, asserting their ownership of a 1,181-square meter parcel of land in Sta. Maria, Bulacan, which was registered in their names since 1976. They contended that DECS's Kaypombo Primary School Annex had occupied a portion of their land with their prior consent but refused to vacate despite demands. DECS claimed that the land occupancy was based on a donation made by respondents' predecessor, Isaias Del Rosario, to the Municipality of Sta. Maria in 1959.
Proceedings and Evidence
During the pre-trial hearing, the existence of the title to the property (TCT No. T-222432) and tax documents was acknowledged by both parties. The trial court conducted a reverse trial where DECS first presented evidence to support its claim of a valid donation. Key witnesses included Ricardo Nicolas, who testified about witnessing the donation, and Judge Eli Natividad, who purportedly prepared the deed of donation. Respondents countered with their own witnesses, including family members of Isaias, who maintained that no formal donation occurred.
Trial Court Judgment
The trial court ruled in favor of DECS, dismissing the respondents’ complaint after finding credibility in the testimonies for the defense. The court concluded that the deed of donation and its acceptance were adequately proven, including the loss of documentation being credible due to mishandling during the Municipality's relocation.
Appeal to the Court of Appeals
Respondents appealed the decision to the Court of Appeals, which reversed the trial court's ruling. The appellate court determined that DECS had failed to satisfactorily establish the existence of the deed of donation and the accompanying municipal resolution. It pointed to a lack of diligent efforts by DECS in searching for the alleged lost documents, thus questioning the basis of their claim.
Legal Issue Addressed
The primary legal question was whether the Court of Appeals erred in ruling that DECS could not prove the existence of the deed of donation and the resolution from the municipal council accepting said donation. The Solicitor General argued that DECS sufficiently demonstrated through secondary evidence the valid donation and the circumstances surrounding the loss of documents.
Court's Ruling
The Supreme Court upheld the decision of the Court of Appeals, agreeing that DECS did not adequately prove the existence or due execution of the necessary documentation to establish a legal donation. Furt
...continue readingCase Syllabus (G.R. No. 146586)
The Case
- This case involves a petition for review aimed at overturning the Decision dated September 25, 2000, and the Resolution dated December 29, 2000, of the Court of Appeals in CA-G.R. CV No. 43929.
- The Court of Appeals reversed the Decision dated July 7, 1993, of the Regional Trial Court of Bulacan, Branch 8, in Civil Case No. 70-M-92.
The Facts
- On February 14, 1992, the respondents filed a complaint for Recovery of Possession against the petitioner, the Department of Education, Culture and Sports (DECS).
- The respondents claim ownership of a parcel of land (1,181 square meters) in Kaypombo, Sta. Maria, Bulacan, registered under Transfer Certificate of Title No. T-222432 since 1976.
- They alleged that the Kaypombo Primary School Annex (KPPS) was occupying a portion of their property with their consent, but KPPS refused to vacate despite demands.
- DECS countered that the KPPS's occupation was based on a donation made by the respondents' father, Isaias Del Rosario, to the Municipality of Sta. Maria in 1959.
- Atty. Ely Natividad, who later became a regional trial court judge, prepared the deed of donation, and KPPS began occupying the donated site in 1962.
- The trial court admitted the existence of TCT No. T-222432, Tax Declaration No. 6310, and tax receipts in the respondents' names for 1991 and 1992.
Evidence Presented
- DECS presented three witnesses (Ricardo Nicolas, Vidal De Jesus, and Judge Natividad), who testified to the donation's existence.
- The trial court summarized their testimonies, indicating that the donation was publicly