Case Summary (G.R. No. L-46573)
Factual Background
The respondent, Dolores Santillan Zabala, initiated the dispute by filing a complaint for recovery of real property and damages with the Court of First Instance of Leyte, asserting her registered ownership of Lot No. 5517, which was covered by Original Certificate of Title (OCT) No. 10782. The property records indicate that the lot is located on Sto. Nino Street and encompasses an area of 164 square meters. The respondent claimed that the petitioners occupied Lot No. 5517 without authorization after illegally extending their occupation from Lot No. 5516, which they legitimately purchased from her in 1936.
Petitioners’ Assertions
The petitioners contended that there was confusion regarding the property sold. They argued that when they agreed to purchase Lot No. 5516, they believed Lot No. 5517 was included based on a sketch provided by the respondent, which they interpreted as covering both lots. They maintained that this shared understanding and their continuous, unchallenged possession of the property over the decades should entitle them to ownership. The petitioners also cited the defense of laches, arguing that the respondent’s long inaction on her part should bar her claims.
Judicial Proceedings and Decisions
Initially, the trial court ruled in favor of the petitioners, dismissing the complaint on the grounds that the evidence suggested mutual understanding between the parties that the sale encompassed both lots. However, the ruling of the trial court was subsequently modified by the Court of Appeals, which partially affirmed the trial court's ruling but ordered the respondent to execute a deed of conveyance for Lot No. 5517 to the petitioners.
Upon reconsideration, the Court of Appeals reversed its earlier decision, asserting the respondent retained ownership of Lot No. 5517 based on the original certificate of title showing no encumbrances and emphasizing the primacy of the written deed over extrinsic documents like sketches. The court noted the improbability that the petitioners could claim ownership without proper documentation supporting such a claim.
Supreme Court Analysis
The Supreme Court reviewed the case and emphasized that the real intention of the parties must be derived from a closer examination of the circumstances surrounding the contract. The findings reinstated the initial ruling by the trial court, emphasizing mutual understanding and acceptance of the sale conditions as evidenced by the letters sent by the respondent with sketches. The Court deemed that even though the deed se
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Case Overview
- This case involves a petition for review on certiorari by petitioners Rev. Fr. Pablo B. Lola and Maxima B. Lola challenging the resolution of the Court of Appeals.
- The appellate court had initially ruled in favor of the petitioners but later reversed its decision, affirming that Lot No. 5517 belongs to private respondent Dolores Santillan Zabala based on her original certificate of title.
Background of the Case
- Private respondent Dolores S. Zabala claimed ownership of Lot No. 5517, covered by Original Certificate of Title No. 10782, located at Sto. Nino Street, Tacloban City.
- She filed a complaint for recovery of real property and damages against the petitioners, alleging that they wrongfully occupied her land after purchasing only Lot No. 5516 from her via a deed of sale executed on June 29, 1936.
- The petitioners, aware they purchased only Lot No. 5516, allegedly occupied Lot No. 5517 in bad faith, constructing improvements thereon.
Respondent's Allegations
- Zabala stated that the petitioners occupied Lot No. 5517, depriving her of its use and rental income.
- She claimed that the petitioners maliciously caused her to sign an affidavit of transfer of real property, unlawfully transferring tax declaration to them.
- Despite her demands, the petitioners refused to vacate Lot No. 5517.
Petitioners' Defense
- The petitioners denied most allegations and argued that they had a legitimate understanding that the purchase included Lot No. 5517, based on a sketch provided by Zabala.
- They claimed to have occupied the disputed lot for over thirty years, asserting that Zabala was estopped from claiming rights due to her inaction.
Trial Court's Decision
- The Court of First Instance of Leyte ruled in favor of the petitioners, dismissing Z