Title
Heirs of Oclarit vs. Court of Appeals
Case
G.R. No. 96644
Decision Date
Jun 17, 1994
Heirs claim land ownership via tax declarations; discrepancies found. Balasabas asserts inherited title. Courts dismiss heirs’ claim, reverse Balasabas's ownership; tax records alone insufficient.
ownership
land
legal title
A

Case Summary (G.R. No. 161833)

Acquisition, Alleged Ownership, and Private Respondent’s Alleged Acts

Petitioners alleged that their predecessor-in-interest, Juan Oclarit, purchased an unregistered parcel of land in 1953 from Martin Macalos for P100.00. The deed of sale described the property only by reference to adjoining lands: bounded on the north and east by the property of Herminigildo Baja, on the south by Mariano Gales, and on the west by a brook, with no permanent landmarks or boundaries.

In 1956, Oclarit allegedly purchased five more parcels in Antipolo and Ulbujan within Garcia-Hernandez, Bohol, from Dalmacio Gales for P600.00. One parcel, referred to as Parcel IV, was described as irrigated rice and coconut land bounded on the north by the land of Leon Macalos, east by the land of Mariano Gales, south by the land of Pablo Gales, and west by the land of Saturnino Gales; it contained an area of 9 ares and 28 centares, more or less, and was stated to have no visible landmarks for the boundaries. Parcel IV was said to be covered by Tax Declaration No. R-19915, transferred and declared under the name of Juan Oclarit, with an assessed value of P30.00.

Petitioners further alleged that in January 1969, private respondent Zacarias Balasabas entered the properties. They claimed that private respondent failed to work on the area planted to palay, climbed the coconut trees, replaced J.O. markings with F.G., representing Felipa Gales, who was said to be his mother, and caused the cadastral survey to record Felipa Gales as a claimant against Juan Oclarit. Petitioners considered these acts as casting a cloud on their title and depriving them of the fruits of the coconut trees. They also asserted that Juan Oclarit had exercised dominion and ownership openly, peacefully, adversely, and uninterruptedly from the time of acquisition, and that he planted coconut trees and other crops, enjoyed their produce, and paid realty taxes, which were continued by his heirs after his death.

Private Respondent’s Answer and the Claim of Ownership Through Inheritance and Purchase

Private respondent denied petitioners’ claim and asserted long, lawful possession. He alleged ownership derived from his mother, Felipa Gales, by inheritance, for the first parcel, and that it was declared in her name under Tax Declaration No. D-1120. For the second parcel, he claimed he acquired it from his own mother through a deed of absolute sale executed on March 20, 1963, and he declared it in his name under Tax Declaration No. D-1006.

He further alleged that he possessed both parcels openly, peacefully, adversely, and continuously without disturbance until he was allegedly molested by petitioners’ heirs. He also argued that Juan Oclarit had surreptitiously declared these lands for taxation in his own name.

Trial Court Proceedings: Appointment of Commissioner and Relocation Survey

During the proceedings, the trial court appointed Teotimo Borja, Deputy Provincial Assessor of Bohol, as commissioner to determine whether the lands described in petitioners’ tax declarations (Tax Declarations Nos. D-13935 and D-13926) overlapped with the lands described by private respondent’s affirmative defenses and covered by his tax declarations (Tax Declarations Nos. D-1120 and D-1006).

In 1978, the commissioner conducted a relocation survey and ocular inspection in the presence of petitioners’ heirs and their counsel, private respondent, a policeman, and adjoining owners including Procopio Oclarit, Galicana J. Pagaran, Maxima Macula, Felipe Macula, and some disinterested persons. In his report dated May 25, 1979, the commissioner observed that both sides claimed parcels based on overlapping portions of annexed cadastral survey figures and traced these figures to files in the Bureau of Lands Office in Jagna, Bohol. He noted that lot numbers had not yet been assigned and traverse computations were pending. He also recorded area discrepancies between what petitioners’ tax declarations indicated and what private respondent’s tax declarations indicated for the same portions of the survey.

Commissioner’s Findings and the Trial Court’s Assessment

The commissioner’s report reflected that petitioners’ tax declaration No. D-13935 corresponded to an area of approximately 3,639 square meters (or 0.3639 ha.) from the annexed survey outline, while the tax declaration itself reflected 0.0928 ha. For private respondent’s tax declaration No. D-1120, the commissioner reported an area of approximately 1,420 square meters (or 0.1420 ha.) more or less, though the tax declaration showed 0.44010 ha.

For the second parcel, the commissioner reported that both parties claimed the same parcel in the western portion of the annexed survey titled “FRANCISCA MACALOS VS. ZACARIAS BALASABAS”. For this parcel, petitioners’ tax declaration No. D-13926 indicated 0.0204 ha., while private respondent’s tax declaration No. D-1006 indicated 0.8147 ha. The commissioner reported physical characteristics and described the terrain as generally hilly, with many coconut trees, some still non-bearing.

Relying on these findings, the trial court expressed surprise at the magnitude of the discrepancies between petitioners’ claimed areas as reflected in the commissioner’s traced survey outlines and the smaller areas stated in their tax declarations. While recognizing that areas in tax declarations were not necessarily approximately exact, the trial court found the discrepancies too obvious to be attributed to any justifiable explanation. It also doubted petitioners’ credibility because petitioners failed to explain why the adjoining owners they claimed were different from those reflected in the commissioner’s survey. The trial court reasoned that, if petitioners were truly the owners of the alleged parcels, they would have taken steps to correct the smaller areas stated in their tax declarations.

Trial Court Ruling

The trial court ruled for private respondent after finding a preponderance of evidence in his favor. It dismissed petitioners’ complaint and declared private respondent the owner of the lots covered by Tax Declarations Nos. D-1120 and D-1006, with areas reflected in the decision as 0.4010 hectare and 0.8147 hectare, respectively. It further ordered petitioners to recognize private respondent’s ownership, to pay attorneys’ fees of P500.00, litigation expenses of P400.00, and to pay the costs of the proceedings.

Court of Appeals Review and Modifications

On appeal, the Court of Appeals held that petitioners failed to prove either legal or equitable title to the two parcels of land necessary in an action for quieting of title. It agreed with the principle that petitioners’ claim of ownership, based principally on tax declarations, was not conclusive.

However, the Court of Appeals disagreed with the trial court’s declaration that private respondent should be recognized as owner. It considered the trial court’s conclusion bereft of convincing evidence because tax receipts, tax declarations, and survey plans were not conclusive and indisputable bases of ownership. Consequently, while it affirmed the dismissal of the complaint, it reversed and set aside the portions declaring private respondent as owner and ordering attorneys’ fees, litigation expenses, and costs.

Petitioners sought reconsideration, but their motion was denied. Private respondent did not appeal the Court of Appeals’ reversal of the ownership declarations.

Petitioners’ Contentions in the Supreme Court

Petitioners assailed the factual findings of the courts below. Their principal contentions were: first, that the filing of Civil Case No. 3103 was the only legal remedy available against private respondent’s alleged malicious acts; second, that Juan Oclarit’s undisturbed claim had continued for more than ten years until disturbance in 1969, thus negating private respondent’s basis for challenging title; third, that the two parcels mentioned by private respondent were foreign and alien to the parcels that Oclarit bought from Martin Macalos and Dalmacio Gales, and that because the vendors had been in possession from time immemorial, prescription had set in; fourth, that the Court of Appeals allegedly failed to appreciate certain exhibits which, according to petitioners, would have shown clear ownership since the description in those exhibits allegedly matched the complaint; and fifth, that the trial court had relied on Ramos v. Court of Appeals (112 SCRA 543) for the proposition that tax receipts were strong evidence of possession because no one would pay realty taxes year after year for property not actually possessed.

Supreme Court’s Treatment of Factual Issues and Identity of the Property

The Supreme Court held that petitioners’ attempts to re-litigate factual findings did not warrant review. It invoked the general rule that factual findings of the Court of Appeals are binding and are not reviewable, absent a showing that both courts overlooked essential facts that would have changed the outcome. It found no such basis after a careful review of the decisions below.

The Court also emphasized that credibility and evidentiary weight are matters best addressed by the trial judge who had the opportunity to observe the witnesses. In civil cases, it stated, the party with the preponderance of evidence prevails, and it was too late for petitioners to claim that the parcels bought by Oclarit were different or alien from those allegedly acquired by private respondent, because petitioners’ contention raised a purely factual issue outside the Court’s ambit.

The Court further noted that the trial court had appointed a commissioner specifically to identify the parcels with particularity, and that the relocation survey and ocular inspection were conducted in petitioners’ presence. The Court reasoned that if petitioners possessed solid evidence that the claimed parcels were alien to those declared by private respondent, they should have questioned the commissioner’s report based on

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