Case Summary (G.R. No. 130546)
Procedural History and Complaint
On October 26, 2009, the Petitioner filed a Complaint for Recovery of Possession and Use of Real Property and Damages before the Regional Trial Court (RTC) of Midsayap, alleging that CAMACOP unlawfully occupied the subject property since 1962 for church activities. The Petitioner asserted ownership, as heir of the registered owners (the Cardenases), and contended that CAMACOP failed to heed repeated demands to vacate. CAMACOP admitted occupying the property but claimed lawful ownership by alleging a valid sale from Pastora Cardenas in 1962 supported by copies of a Deed of Sale submitted to the Department of Agriculture and Natural Resources (DENR).
RTC Decision
The RTC dismissed the Petitioner’s complaint on June 6, 2012, ruling in favor of CAMACOP. It found credible CAMACOP’s evidence that a valid sale transpired, transferring ownership from Pastora Cardenas to CAMACOP. The Petitioner appealed the decision to the Court of Appeals (CA).
Court of Appeals Ruling
The CA denied the Petitioner’s appeal, affirming the RTC’s finding that a valid sale existed. The CA held that the Petitioner failed to prove ownership by a preponderance of evidence and ruled in favor of CAMACOP’s possession and ownership claim. A subsequent motion for reconsideration by the Petitioner was denied.
Issue Presented
The core issue is whether the Petitioner, as the heir, has the better right to possess the subject property over CAMACOP, considering the alleged sale and continuous occupation by CAMACOP since 1962.
Supreme Court’s Review of Evidence
While the Court generally defers to the findings of fact by lower courts, it may review them when such findings are unsupported or constitute grave abuse of discretion. This case concerns an action for recovery of possession of real property, which requires the plaintiff to prove a positive right of possession, not merely the defendant’s lack of title.
The Court found that the Petitioner sufficiently established a positive right of possession by presenting uncontroverted evidence that the subject property was still titled in the names of Pastora and Eustaquio Cardenas. This included the TCT, tax declarations, tax payments, and real property tax clearances. These are considered prima facie evidence of ownership and possession rights.
CAMACOP’s Burden of Proof and Inadequacy of Evidence
The Court noted that the burden shifted to CAMACOP to prove the validity of their ownership claim based on the alleged 1962 sale by Pastora Cardenas. CAMACOP relied on the absence of the original Deed of Sale, claiming all copies were submitted to the then Department of Agriculture and Natural Resources (DENR). To prove the contents of the lost document, CAMACOP needed secondary evidence presented in compliance with Section 5, Rule 130 of the Revised Rules on Evidence, which allows for (1) copies of the lost document, (2) authentic documents containing a recital of its contents, or (3) credible witness testimony in that order.
CAMACOP failed to provide any original or authenticated copies of the Deed of Sale, nor any authentic document reciting its contents. CAMACOP submitted self-serving letters and affidavits that did not satisfy evidentiary requirements, were hearsay, lacked authenticity, or contained inconsistent or uncorroborated statements. Notably, the alleged notarial register recording the Deed was never produced, and no attempt was made to compel the Department to produce copies. The Court found this failure implausible and undermined the credibility of CAMACOP’s claim.
Witness Testimonies and Discrepancies
Witnesses presented by CAMACOP were incompetent to testify on the validity or existence of the Deed of Sale. Two admitted they lacked personal knowledge or never saw the contract. The only witness with such knowledge, Eudecia M. Repollo, testified that CAMACOP had actually purchased only 110 square meters of the property—not the entire 410 square meters subject to the suit.
The Court considered this testimony critical because CAMACOP’s occupied area exceeded the size supposedly sold. The Petitioner conceded CAMACOP’s right to possess the 110-square-meter parcel but contested occupation of the remaining 300 square meters.
Affirmation of the Petitioner’s Ownership and Rejection of Prescription and Laches Defenses
The Court reiterated the principle under Section 47 of Presidential Decree No. 1529 that registered land ownership is indefeasible and cannot be lost by prescription or adverse possession. Ownership of registere
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Case Background and Parties Involved
- The petitioner is Remedios Cardenas-Tumlos (Remedios), heir of spouses Pastora T. Cardenas and Eustaquio Cardenas (collectively Sps. Cardenas), represented by her attorney-in-fact, Janet Tumlos-Quizon (Janet), her daughter.
- The respondent is The Christian and Missionary Alliance Churches of the Philippines, Inc. (CAMACOP), represented by Reo Repollo and Leocadio Duque, Jr.
- The controversy concerns ownership and possession over Lot 90, Psd-37322, a 410-square-meter parcel of land located at Poblacion 6, Midsayap, Cotabato, covered by Transfer Certificate of Title (TCT) No. T-6097 and Tax Declaration No. K-019938 ("subject property").
- CAMACOP’s church is situated adjacent to this lot, on Lot 3924-A, Psd-12-013791.
Procedural History
- On October 26, 2009, Janet filed a Complaint for Recovery of Possession and Use of Real Property and Damages before the Regional Trial Court (RTC) of Midsayap, Cotabato, Branch 24 (Civil Case No. 09-033).
- CAMACOP admitted ownership of the adjacent lot but claimed lawful acquisition of the subject property by a 1962 sale from Pastora.
- RTC ruled in favor of CAMACOP on June 6, 2012, dismissing the complaint for lack of merit.
- Janet filed an appeal; the Court of Appeals (CA) affirmed the RTC's decision in its February 16, 2015 judgment.
- Motion for Reconsideration by Janet was denied by the CA on December 2, 2015.
- The petition for review on certiorari to the Supreme Court followed, raising questions of possession rights over the subject property.
Core Issue
- The pivotal issue is which party, the Heir of Sps. Cardenas or CAMACOP, holds the better right to possess the subject property.
Legal Principles Cited
- The Supreme Court generally defers to lower courts' factual findings unless these are unsupported by evidence or constitute grave abuse of discretion.
- Recovery of possession requires establishing positive rights, not merely the absence of the defendant’s title.
- TCT serves as evidence of an indefeasible title in favor of the registered owner.
- Prescription and laches doctrines do not create ownership over registered land in derogation of the registered owner’s title (P.D. 1529, Section 47).
- Laches is an equitable doctrine focused on prejudice arising from delay, distinguished from statutory prescription.
- Secondary evidence may be used only under strict conditions when original documents are lost or unavailable without bad faith, and proper authentication is required for private documents.
Factual Findings on Possession and Ownership
- Uncontroverted fact: Lot 90 covered by TCT No. T-6097 is still registered in the names of the late spouses Pastora and Eustaquio Cardenas.
- Remedios is the compulsory heir and only daughter of the registered owners.
- Tax Declarations, Real Property Tax Clear