Case Summary (G.R. No. 71283)
Petitioner
Heirs of the deceased cadastral claimant, Miguel Escritor, who occupied Lot No. 2749 after the cadastral court adjudicated the lot in favor of their predecessor and who subsequently were ordered to vacate after later proceedings in favor of respondent Acuna.
Respondent
Simeon S. Acuna, who challenged the cadastral adjudication and later secured a readjudication in his favor, and who sued petitioners for recovery of damages for fruits allegedly received during their possession.
Key Dates
- May 15, 1958: Cadastral Court (Cadastral Case No. 72) adjudicated Lot No. 2749 to claimant Miguel Escritor (Exhibit B).
- July 15, 1958: Order directing issuance of decree of registration (Exhibit C).
- August 2, 1958: Acuna filed petition for review alleging fraud (Exhibit D).
- July 18, 1960: Petition for review granted; new hearing set (Exhibit E).
- February 16, 1971: Cadastral court adjudicated Lot No. 2749 in favor of Acuna (Exhibit F).
- October 13, 1975: Acuna filed Civil Case No. 1138-G (complaint for recovery of damages for fruits).
Applicable Law
- Provisions of the Civil Code cited in the record: Article 526 (definition/character of possessor in bad faith), Article 527 (presumption of good faith), and Article 534 (non-transmissibility of consequences of wrongful possession to heirs). Legal maxims and authorities referenced include Tolentino’s commentary and prior jurisprudence (Sotto v. Enage, CA).
Facts
Lot No. 2749 underwent cadastral proceedings in which Miguel Escritor filed an answer claiming ownership by inheritance; notice of hearing was published and an order of general default was entered, leaving Escritor as the sole party to present evidence. The cadastral court found Escritor’s ownership established and adjudicated the lot to him on May 15, 1958; an order for issuance of decree of registration followed. Escritor took possession. Acuna later petitioned for review alleging fraud; proceedings were reopened, and after further hearings the cadastral court readjudicated the lot to Acuna in 1971. Escritor died during the pendency of the reopened cadastral proceedings; his heirs (petitioners) remained in possession until ordered out, then voluntarily vacated. Acuna sued petitioners in 1975 for recovery of the value of fruits allegedly received during their 13 years of possession.
Procedural History
- Cadastral adjudication in favor of Escritor (1958) became the basis for possession.
- Acuna filed petition for review (1958); review granted and hearing set (1960).
- Final readjudication in favor of Acuna (1971); writ of possession issued and petitioners vacated (Exhibit H).
- Acuna filed complaint for damages in Civil Case No. 1138-G (1975); trial court dismissed complaint on grounds of good faith possession under just title and prescription.
- Intermediate Appellate Court reversed (1984), ordering petitioners to pay value of fruits and attorney’s fees.
- Petitioners sought review by certiorari, raising principally the question of their liability for damages.
Issue Presented
Whether petitioners (heirs of Escritor) are liable to respondent Acuna for the value of fruits received during their possession of Lot No. 2749, specifically whether they were possessors in bad faith and therefore accountable for such damages.
Court’s Findings on Possession and Title
The Court found that the first cadastral decision of May 15, 1958 adjudicated the lot to Escritor after hearing his uncontested evidence of ownership, finding open, public, continuous, adverse, exclusive, and notorious possession dating back to the Filipino-Spanish Revolution (Exhibit B). The order of July 15, 1958 declared that decision final. On this basis, Escritor had an honest, well-grounded belief in his ownership and continued possession of the land. The record contained no evidence establishing that Escritor or his heirs knew of a defect in title or that the adjudication was procured by fraud.
Burden of Proof and Presumptions
Under the Civil Code, good faith is presumed (Article 527), and the party alleging bad faith bears the burden of proof. The Court emphasized that Acuna, as plaintiff seeking damages based on alleged bad faith and fraud, failed to present evidence proving either that Escritor or his heirs knew of a defect in title or that the cadastral adjudication was obtained by fraud. The presumption of good faith therefore remained intact.
Fraud Allegation and Failure of Proof
Acuna’s allegation that the cadastral registration was effectuated through fraud and misrepresentation was not substantiated in the cadastral proceedings nor in the trial on damages. The record shows the lot became uncontested and Escritor was permitted to present evidence on January 22, 1958; Acuna’s absence at that hearing was attributed to a misunderstanding with a lawyer (Exhibit E), and there is no evidence that petitioners or their predecessor caused Acuna’s failure to appear. Publication requirements for notice of hearing were complied with. Consequently, the Court concluded the fraud allegation lacked a factual basis in the record.
Non-Transmissibility of Bad Faith
The Court applied Article 534 of the Ci
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Procedural Posture
- Petition for review on certiorari brought to the Supreme Court seeking reversal of the Intermediate Appellate Court decision in AC-G.R. No. CV-01264-R (entitled "Simeon Acuna vs. Miguel Escritor, Jr., et al."), from an original case in the Court of First Instance of Quezon, Gumaca Branch.
- Cadastral proceedings (Cadastral Case No. 72) resulted in a May 15, 1958 decision adjudicating Lot No. 2749 to claimant Miguel Escritor; an Order for issuance of decrees was entered July 15, 1958.
- Respondent Simeon S. Acuna filed a petition for review on August 2, 1958; that petition was granted July 18, 1960, and a new hearing set for September 13, 1960.
- After further proceedings, on February 16, 1971 the cadastral court readjudicated Lot No. 2749 in favor of Acuna and ordered petitioners to vacate; a writ of possession was later issued and petitioners vacated.
- On October 13, 1975, Acuna filed Civil Case No. 1138-G for recovery of damages for fruits allegedly received by petitioners during their 13 years of possession.
- The trial court dismissed Acuna's complaint for damages; on appeal, the Intermediate Appellate Court reversed (October 31, 1984), ordering petitioners to pay Php 10,725.00 (value of fruits for 13 years), Php 3,000.00 (attorney's fees), and costs.
- The present petition challenges the Intermediate Appellate Court's reversal and seeks reinstatement of the trial court's dismissal.
Relevant Facts
- Subject property: Lot No. 2749, located at Atimonan, Quezon, the subject of cadastral proceedings before the Court of First Instance of Quezon, Gumaca Branch.
- Claimant: Miguel Escritor filed an answer in the cadastral proceedings, declaring ownership by inheritance from his deceased father (Exhibit "A").
- Procedural history in cadastral case: notice of hearing published; an order of general default entered; lot became uncontested; Escritor appeared to adduce evidence (hearing January 22, 1958) and the court rendered decision May 15, 1958 in his favor (Exhibit "B").
- Possession: Escritor took possession immediately after the May 15, 1958 decision and continued possession thereafter.
- Administrative step: July 15, 1958 court Order directed the Chief of the General Land Registration Office to issue the corresponding decree of registration in favor of Escritor (Exhibit "C").
- Challenge: On August 2, 1958 Acuna filed a petition for review alleging the decision was obtained by fraud and misrepresentation (Exhibit "D"); petition granted July 18, 1960 and new hearing set (Exhibit "E").
- Death of claimant: While proceedings continued, claimant Miguel Escritor died; his heirs (petitioners) took possession of the property.
- Readjudication: On February 16, 1971, the cadastral court adjudicated the lot in favor of Acuna and ordered petitioners to vacate (Exhibit "F"); writ of possession issued (Exhibit "H") and petitioners voluntarily vacated.
- Civil action for damages: On October 13, 1975 Acuna filed Civil Case No. 1138-G against petitioners for recovery of fruits for the 13 years petitioners allegedly possessed the land unlawfully.
- Trial court: Dismissed Acuna’s complaint, finding petitioners possessed in good faith, under a just title, and that any cause of action had prescribed (Record on Appeal, p. 11).
- Intermediate Appellate Court: Reversed the trial court on October 31, 1984 (dispositive awarding Php 10,725.00, Php 3,000.00 attorney’s fees, and costs) on the ground petitioners were possessors in bad faith from 1958 to 1971 and must reimburse fruits (Rollo, pp. 26-27).
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