Case Summary (G.R. No. 145284)
Jurisdiction and Nature of the Case
The case arises from a complaint filed by Iriola on June 2, 1954, seeking a declaration of ownership and a reconveyance of a parcel of land he claims to have owned and possessed adversely for over ten years. The land, described in detail in the complaint, is located in the Barrio of Bagong Sirang, Pili, Camarines Sur. The defendant, Felices, counters the claim by asserting his registered ownership of a larger parcel covered by a Certificate of Title that includes the land in question.
Pleadings and Motions
Following the filing of the complaint, Felices filed his answer on June 23, 1954, contesting Iriola’s ownership and asserting that Iriola was estopped from claiming ownership as he had acknowledged that the contested parcel forms part of Felices’ titled land. A conditional sale of a portion of the property had previously occurred on February 24, 1949, wherein Felices sold a portion of land to Iriola.
Underlying Issues of Ownership
The core issue revolves around the legitimacy of Felices’ Certificate of Title which Iriola claims includes his portion of land obtained through adverse possession. Iriola asserts that Felices fraudulently included this land in his homestead application, leading to his action for reconveyance. In juxtaposition, Felices contends that Iriola occupied more land than what was conditionally sold to him, thus unlawfully depriving Felices of possession.
Estoppel and Evidentiary Admission
During the trial, Felices moved to strike the testimony of Iriola’s witness on the grounds of estoppel, arguing that Iriola had acknowledged the land's inclusion in the title deed. The trial court agreed, interpreting Iriola’s admission in the conditional sale as an acknowledgment that the land belonged to Felices. The court concluded that Iriola was estopped from proving ownership and barred him from presenting evidence of it.
Supreme Court’s Analysis
Upon appeal, the Supreme Court scrutinized the lower court's ruling. The Court indicated that Iriola's admissions in the conditional sale were vague and
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Case Background
- The case involves an appeal by Mamerto Iriola (plaintiff-appellant) against Silverio Felices (defendant-appellee) regarding ownership and reconveyance of a parcel of land.
- The case is docketed as Civil Case No. 2667 in the Court of First Instance of Camarines Sur, Branch I.
- The lower court issued an order preventing Iriola from presenting evidence of ownership based on the principle of estoppel.
Facts of the Case
- Iriola claims ownership of a parcel of land located in Barrio Bagong Sirang, Pili, Camarines Sur, based on over ten years of possession by himself and his predecessors.
- The contested land is a smaller parcel, part of a larger area that Felices claims under a homestead patent.
- Iriola alleges that Felices fraudulently obtained a Certificate of Title (No. 104) for a larger parcel that includes Iriola's claimed property.
Defendant's Position
- Felices denies Iriola's claims and asserts that he is the registered owner of the entire parcel, including the contested smaller portion.
- He argues that Iriola unlawfully took possession of more land than he was entitled to under a conditional sale agreement made in 1949.
- Felices contends that Iriola is estopped from claiming ownership of the contested land due to his acknowled