Case Summary (G.R. No. 79597-98)
Procedural History
Two consolidated actions originated in the Regional Trial Court (RTC) of Guagua, Pampanga: Civil Case No. G-1190 (recovery of possession, damages, preliminary injunction) and Civil Case No. G-1332 (cancellation of title, ownership with damages, preliminary injunction). RTC rendered judgment for the private respondents (heirs of Inocencio Songco), dismissing both complaints, ordering cancellation of OCT No. RO-1038 (11725), restoration of possession to defendants, and awarding moral, exemplary damages, attorney’s fees and costs. The petitioners appealed to the Court of Appeals (CA), which affirmed with modification (removing awards for moral/exemplary damages and attorney’s fees). Petitioners filed for reconsideration in the CA which was denied; they then filed the present petition for review on certiorari to the Supreme Court.
Facts Alleged by Petitioners
Petitioners alleged they are heirs of Demetria Lacsa, original owner of the disputed parcel. They alleged the respondents and their predecessors fraudulently occupied the fishpond portion of the land through stealth and machination, used and expanded occupancy, and refused to vacate. In Civil Case No. G-1332 petitioners alleged that respondents’ predecessor-in-interest (Inocencio Songco) presented forged and simulated documents—specifically a “Traduccion al Castellano de la Escritura de Particion Extrajudicial” (Apr. 7, 1923) and an “Escritura de Venta Absoluta” (Jan. 20, 1924)—to the Register of Deeds, resulting in transfer of title to Inocencio Songco and prejudice to petitioners.
Respondents’ Allegations and Counterclaim
Respondents denied the material allegations and asserted OCT No. RO-1038 had been superseded by Transfer Certificate of Title (TCT) No. 794 in favor of Alberta Guevarra and Juan Limpin pursuant to an extrajudicial partition, and subsequently superseded by TCT No. 929 issued to Inocencio Songco based on a valid vendita (Escritura de Venta Absoluta). They pleaded that petitioners lacked cause of action, and counterclaimed for damages alleging illegal occupation by petitioners’ agents, depletion of fish stock and consequential losses, and sought actual, moral, exemplary damages, attorney’s fees and appearance fees.
Stipulation of Facts Between Parties
On January 20, 1985, the parties executed a joint stipulation of facts acknowledging: (1) the filing of Civil Case No. G-1190 by petitioners on June 9, 1982; (2) denial of leave to file an amended complaint, prompting the filing of Civil Case No. G-1332 with the same cause of action; (3) that the evidence in both cases was practically identical; and (4) agreement that evidence presented in Civil Case No. G-1190 would be adopted for Civil Case No. G-1332 and submission of both cases would be based on the same evidence. The stipulation was treated as binding for evidentiary purposes by the RTC.
RTC Findings of Fact
The RTC found that the disputed fishpond originally belonged to Demetria Lacsa under OCT No. 11725. After her death, her properties were partitioned by extrajudicial instruments (including the Spanish “Traduccion” dated Apr. 7, 1923 and a Pampango translation) adjudicating the fishpond to Alberta Guevarra, resulting in TCT No. 794 issued to Alberta and Juan Limpin. The RTC further found a sale by Alberta and Juan Limpin to Inocencio Songco (the “Escritura de Venta Absoluta” dated Jan. 20, 1924) that was duly registered, causing cancellation of TCT No. 794 and issuance of TCT No. 929 to Inocencio Songco. Based on these recorded documents, the RTC concluded the fishpond belonged to private respondents as heirs of Inocencio Songco.
RTC Judgment and Reliefs
The RTC dismissed petitioners’ complaints in both Civil Case Nos. G-1190 and G-1332; ordered cancellation of OCT No. RO-1038 (11725) in the name of Demetria Lacsa; ordered petitioners to restore possession to defendants; awarded P25,000 moral damages, P25,000 exemplary damages, P10,000 attorney’s fees to defendants; and imposed costs against petitioners.
Court of Appeals Ruling
On appeal, the Court of Appeals affirmed the RTC decision but modified it by removing the awards of moral and exemplary damages and attorney’s fees against petitioners. The CA’s decision thus sustained the factual and legal determinations of the RTC concerning ownership and validity of titles and recorded documents.
Issues Raised in the Petition to the Supreme Court
Petitioners primarily contended that the CA erred by: (1) applying the “ancient document rule” (Sec. 22, Rule 132, Rules of Court) to Exhibits 3 (Traduccion de Particion) and 7 (Escritura de Venta Absoluta); (2) disregarding mandatory requirements of the 1903 Notarial Law; and (3) disregarding the rule on proof of public or official record (Sec. 25, Rule 132). Petitioners argued Exhibits 3 and 7 could not qualify as “ancient documents” because first pages lacked signatures (creating a blemish) and because the documents did not comply with notarial/registration formalities, rendering them susceptible to substitution or forgery.
Supreme Court Analysis — Ancient Document Rule
The Supreme Court recalled the requirements of Sec. 22, Rule 132: a private writing over thirty years old, produced from a custody in which it would naturally be found if genuine, and unblemished by alterations or circumstances of suspicion, requires no further proof of execution or authenticity. The Court observed that Exhibits 3 and 7 were executed in 1923 and 1924 respectively (over thirty years old). Both were certified as exact copies of origin
...continue readingCase Syllabus (G.R. No. 79597-98)
Case Caption, Citation and Decision Date
- Reported in 274 Phil. 506, Second Division, G.R. Nos. 79597-98.
- Decision rendered May 20, 1991.
- Petition for review on certiorari from the decision of the Court of Appeals in CA-G.R. CV Nos. 08397-08398 dated July 16, 1987, which affirmed with modification the judgment of the Regional Trial Court (RTC) of Guagua, Pampanga.
- The petition to the Supreme Court challenged the Court of Appeals' decision and its denial of the motion for reconsideration by resolution dated August 14, 1987.
Nature of the Action and Parties
- Petitioners: Heirs of Demetria Lacsa, represented by Bienvenido Cabais, Virginia Cabais, Leonor Cabais-Pena and Dolores Cabais-Magpayo.
- Respondents: Court of Appeals and private respondents who are heirs of Inocencio Songco, including Aurelio D. Songco and numerous others.
- The case originated in the RTC of Guagua, Pampanga and involves two civil cases consolidated for resolution: Civil Case No. G-1190 and Civil Case No. G-1332.
Facts Alleged by Petitioners (Plaintiffs in the lower court)
- Petitioners asserted they are heirs of Demetria Lacsa, who during her lifetime owned a parcel of land in Bancal, Guagua, Pampanga, partly a fishpond and partly uncultivated open space, evidenced by Original Certificate of Title (OCT) No. RO-1038 (11725).
- In Civil Case No. G-1190, petitioners sought recovery of possession with damages and preliminary injunction against Aurelio Songco and John Doe, alleging that the principal respondent and his predecessor-in-interest, not being co-owners or tenants, occupied the fishpond by stealth, fraud and other machinations, cleared the open space for expanded occupancy, and refused to vacate despite demands.
- In Civil Case No. G-1332, petitioners sought cancellation of title, ownership with damages and preliminary injunction, alleging that private respondents and predecessors-in-interest occupied the fishpond, later abandoned it only after filing suit and after transferring fish to adjoining fishpond owned by private respondents.
- Petitioners alleged that on October 31, 1923 and March 15, 1924, Inocencio Songco presented forged and simulated documents to the Register of Deeds of Pampanga — titled "TRADUCCION AL CASTELLANO DE LA ESCRITURA DE PARTICION EXTRAJUDICIAL" and "ESCRITURA DE VENTA ABSOLUTA" — thereby transferring title to himself to petitioners' damage and prejudice.
- Petitioners asserted necessity of a preliminary injunction to prevent private respondents from disposing of the property.
Respondents' Denials and Counterclaims
- Private respondents denied material allegations and raised special and affirmative defenses, contending petitioners lacked cause of action because OCT No. RO-1038 (11725) was a reconstituted copy issued in April 1983 and had been long cancelled and superseded by TCT No. 794 in the names of Alberta Guevarra and Juan Limpin by virtue of the "TRADUCCION..." partition by heirs of Demetria Lacsa.
- Respondents further alleged TCT No. 794 was superseded by TCT No. 929 issued in the name of Inocencio Songco by virtue of the "ESCRITURA DE VENTA ABSOLUTA" executed by spouses Juan Limpin and Alberta Guevarra in favor of Inocencio Songco.
- Private respondents filed a counterclaim alleging that petitioners, headed by Carlito Magpayo, by force and intimidation took possession of a portion of the fishpond and occupied a hut therein, harvesting 3,000 bangus fingerlings belonging to private respondents and causing damages amounting to approximately P50,000, loss of unrealized income, sleepless nights, wounded feelings, anxiety, and claimed entitlement to actual, moral and exemplary damages, attorney’s fees and appearance fees.
Joint Stipulation of Facts Between Parties
- On January 20, 1985, parties filed in Civil Case No. G-1332 a joint stipulation of facts that:
- Petitioners filed Civil Case No. G-1190 on June 9, 1982.
- After defendants filed an answer in G-1190 and petitioners' motion to admit amended or supplemental complaint was denied, petitioners filed Civil Case No. G-1332 with essentially the same cause of action as the proposed amendment.
- Evidence in both cases was said to be practically and literally the same.
- Parties mutually agreed that evidences presented under Civil Case No. G-1190 would be adopted for both cases and that upon submission of G-1190, G-1332 would likewise be deemed submitted for resolution on the same evidentiary basis.
Findings and Ruling of the Regional Trial Court (Lower Court)
- The RTC, on the basis of the joint stipulation and the documentary record, found:
- The fishpond was originally owned by Demetria Lacsa under OCT No. 11725.
- After Demetria Lacsa's death, daughters Alberta Guevarra and Ambrocia (Ambrosia) Guevarra and their husbands entered into an extrajudicial partition dated April 7, 1923, titled "Traduccion Al Castellano de la Escritura de Particion Extrajudicial" (Exhs. 3, 3-A, 3-B). That partition adjudicated the fishpond to Alberta Guevarra and was registered in the Office of the Registry of Deeds of Pampanga (Cert. Exh. 3-C).
- A Pampango dialect partition (Exh. 3-D) also adjudicated the fishpond to Alberta Guevarra, resulting in issuance of Original Certificate of Title No. 794 (Exh. 4) to spouses Alberta Guevarra and Juan Limpin.
- On January 20, 1924 (note: elsewhere recorded as dates 31 Oct 1923 and 15 Mar 1924 in petitioners' allegations), spouses Juan Limpin and Alberta Guevarra sold the fishpond to Inocencio Songco under "Escritura de Venta Absolute" (Exhs. 7 and 7-A), which was registered in the Registry of Deeds (Cert. Exh. 7-B), resulting in cancellation of TCT No. 794 and issuance of TCT No. 929 to Inocencio Songco.
- The RTC concluded that the fishpond belonged to private respondents, inherited from their deceased father Inocencio Songco.
RTC Dispositive Relief
- The RTC's dispositive judgment ordered:
- Dismissal of the complaint in Civil Case No. G-1190.
- Dismissal of the complaint in Civil Case No. G-1332.
- Cancellation of Original Certificate of Title No. RO-1038 (11725) in the name of Demetria Lacsa.
- Plaintiffs to restore possession of the fishpond in Bancal, Guagua, Pampanga, to the defendants.
- Plaintiffs to pay jointly and severally to defendants P25,000 as moral damages.
- Plaintiffs to pay jointly and severally to defendants P25,000 as exemplary damages.
- Plaintiffs to pay jointly and severally to defendants P10,000 as attorney’s fees.
- Costs against the plaintiffs.