Case Summary (G.R. No. 198402)
Applicable Law
This case is governed by the 1987 Philippine Constitution, other relevant provisions of the Civil Code of the Philippines on property rights, and procedural laws including Rule 45 of the Rules of Court.
Facts of the Case
The respondents initiated a complaint in July 1985 in the Regional Trial Court (RTC) of Tagbilaran City, seeking to quiet title, recover possession, and obtain damages against several defendants, including Alexander Miel, the husband of petitioner Angeles Racaza Miel. The complaint involved a residential lot claimed to have been acquired by the respondents from the estate of Emilia Garces through a formally executed and registered Deed of Absolute Sale. Following the trial, the RTC ruled in favor of the respondents, granting them ownership and possession of the disputed land.
Upon failing to vacate the property despite court orders, the petitioners initiated their own complaint in January 1991, arguing their co-ownership of the property. The petitioners claimed peaceful and continuous possession of the land, asserting that the previous actions against Alexander Miel were unjust and that the demolition of their ancestral house was improperly handled.
Ruling of the RTC
The RTC dismissed the petitioners' complaint on April 4, 2005, based on several findings: (1) The evidence provided by the respondents, highlighting their long-term possession dating back to 1917, was considered significantly stronger than the tax declaration evidence presented by the petitioners, which only dated back to 1949; (2) Petitioner Angeles Racaza Miel's failure to inform her husband about the proceedings, despite being designated as a co-heir, inferred a lack of genuine interest in challenging the initial litigation; and (3) Prior admissions from Angeles Racaza Miel acknowledging the eviction further diminished their claim.
Ruling of the Court of Appeals
The Court of Appeals upheld the RTC decision on September 8, 2010, and affirmed its findings through a subsequent resolution on August 8, 2011. The appellate court agreed with the trial court’s assessment that the petitioners had not provided sufficient evidence to overturn the previous ruling.
Present Petition
In their petition for review, the petitioners contended that the property was foreshore land owned by the State, that respondents acted in bad faith when purchasing the land, and that the demolition order was unconstitutional and improper. The petitioners sought to submit newly discovered evidence, including a Certification from the Community Environment and Natural Resources Office (CENRO) and a cadastral map, to support their claim regarding the nature of the property.
Supreme Court's Ruling
The Supreme Court denied the petition, stating that it posed questions of fact rather than law—an area beyond the scop
...continue readingCase Syllabus (G.R. No. 198402)
Case Overview
- Petitioners: Heirs of Pacencia Racaza (Virginia Racaza Coscoss, Angeles Racaza Miel, Rodrigo Racaza, Quirino Racaza, Rogelio Racaza, Ernest Racaza, Roland Racaza).
- Respondents: Spouses Florencio and Eleuteria Abay-abay.
- Case Reference: G.R. No. 198402.
- Date of Decision: June 13, 2012.
- Jurisdiction: Second Division of the Supreme Court of the Philippines.
- Nature: Petition for Review on Certiorari under Rule 45 of the Rules of Court.
Background of the Case
- Respondents filed a complaint in July 1985 for quieting of title, recovery of possession, and damages against several defendants, including Alexander Miel, husband of petitioner Angeles Racaza Miel.
- The property in dispute was situated in Poblacion Ubay, Bohol, covered by Tax Declaration No. 4501-663.
- Spouses Abay-abay claimed ownership through a Deed of Absolute Sale dated August 12, 1979, registered on October 10, 1984.
- The complaint arose after the defendants began constructing residential houses on the property without the Abay-abays' consent.
Proceedings in the Regional Trial Court (RTC)
- Alexander Miel was declared in default for failing to answer the complaint.
- On May 30, 1988, the RTC ruled in favor of the Abay-abays, ordering the defendants to vacate the property.
- A writ of execution was issued to demolish structures, including the Miels' house.
- The Miels file