Case Summary (G.R. No. 165014)
Facts of the Case
On October 19, 1993, the respondents initiated an action against the petitioners in the Regional Trial Court (RTC) to reclaim ownership and possession of the subject property, as well as seek damages. They asserted that the land was originally owned by their predecessor, Emiliana Bacalso, as per Decree No. 98992, although the physical decree was supposedly lost during World War II. They presented evidence, including Land Registration Authority (LRA) certification and a daybook entry, to establish their claim, and claimed continued possession until 1988. The petitioners contended that they inherited the property from Remegio Navares, asserting that it was rightfully purchased before the war, despite lacking strong documentation, such as a deed of sale.
Ruling of the RTC
The RTC, in its decision dated June 27, 1997, ruled in favor of the petitioners, acknowledging their claim stemming from tax declarations and payments for the subject property. It noted that while tax declarations do not solely prove ownership, they can imply it when combined with continuous possession. The RTC observed that the respondents failed to take necessary actions to locate their purported title and noted laches on their part for the 55-year delay in claiming ownership.
Ruling of the CA
The Court of Appeals (CA) reversed the RTC's decision on February 28, 2001, finding that the respondents held superior rights to ownership and possession. It highlighted the weakness of the petitioners' evidentiary support, primarily tax declarations, which were deemed inadequate in the absence of proof of actual possession. The CA emphasized the importance of Decree No. 98992, which purportedly establishes the land's ownership, over the petitioners' claims, concluding that respondents demonstrated prior possession and rightful ownership.
Issue Before the Supreme Court
The primary issue at hand was whether the respondents had a superior claim to the ownership and possession of Lot No. 8217 in comparison to the petitioners.
Supreme Court's Ruling
The Supreme Court affirmed the CA's decision, citing that the respondents proved a better claim through Decree No. 98992. The Court noted that a decree of registration bars all claims that arose before its issuance, emphasizing the definitive nature of ownership established by such decrees. The Court found that the petitioners could not substantiate their
...continue readingCase Syllabus (G.R. No. 165014)
Case Overview
- This case involves a petition for review on certiorari filed by the Heirs of Alejandra Delfin against Avelina Rabadon and others.
- The petition seeks to challenge the Decision dated February 28, 2001, and Resolution dated August 2, 2004, of the Court of Appeals (CA) which reversed the ruling of the Regional Trial Court (RTC) regarding ownership and possession of a parcel of land.
Background of the Case
- The subject of the dispute is Lot No. 8217, a 4,452 square meter parcel of land located in Inawayan, Pardo, Cebu City.
- Respondents filed an action in the RTC to recover ownership and possession of the property, alleging that it belonged to their predecessor, Emiliana Bacalso, under Decree No. 98992.
- The respondents claimed that although the original decree was lost during World War II, its existence was evidenced by a certification from the Land Registration Authority (LRA) and a daybook entry from the Register of Deeds.
Respondents' Claims
- Respondents testified that:
- The property was owned by Emiliana Bacalso.
- After Emiliana's death, her heirs possessed the property until 1988.
- They discovered in 1989 that the property was in the possession of Alejandra Delfin and her family, who built houses there.
- Alejandra claimed her predecessor, Remegio Navares, had purchased the property, but failed to provide a deed of sale.
Petitioners' Defense
- Petitioners countered with the following:
- They inherited the property from Remegio, who allegedly purch