Case Summary (G.R. No. 175343)
Background of the Property
The disputed land was originally part of the Y. Furukawa Daliao Plantation and was administered by various government bodies following its turnover to the Philippine government. Loreto Luga had been a tenant of the plantation since 1957 and occupied the parcel in question, building a residence using light materials.
Transfer of Rights and Claims
An Occupant's Affidavit was executed by a former employee of the plantation in 1960, which included the disputed land. Later, rightsholder Honorio Romero transferred portions of the land to Rogelio Arciaga in two transactions during 1970 and 1972. Upon Elena's application for patent/title over the subject parcel, the Board of Liquidators (BOL) issued a notice allowing adverse claimants to establish their claims.
Legal Proceedings
Loreto initially filed a complaint for reconveyance of title and damages against Elena and Rogelio with the Regional Trial Court (RTC) in 1994, asserting possession since 1957 and alleging Elena's fraudulent misrepresentation to the BOL. The respondents denied these allegations, arguing that Loreto's occupation was based on tolerance and consent.
RTC Ruling
The RTC ruled in favor of Loreto, finding that his prior possession entitled him to the land, which was acquired by Elena through fraud. The court ordered the reconveyance of the title to Loreto. This decision was subsequently appealed by the Arciagas.
Court of Appeals Ruling
The Court of Appeals reversed the RTC decision, ruling that the evidence showed Loreto was merely allowed to occupy the property. The CA found that Loreto was not acting in the concept of an owner and had never declared the property for taxation purposes. The CA ruled he did not meet the evidence threshold required for reconveyance.
Petition for Reconsideration and Substitution of Parties
Following the CA's decision, a motion for reconsideration was filed after Loreto's death in 1998, leading to the substitution of parties. This was met with opposition from the Arciagas and was eventually denied by the CA.
Supreme Court Proceedings
The case reached the Supreme Court,
...continue readingCase Syllabus (G.R. No. 175343)
Case Background
- The case involves a petition for review on certiorari filed by the petitioners, Loreto Luga (deceased), substituted by Celerina Luga (deceased) and their children.
- The petition challenges the Decision dated 25 October 2005 of the Special Twenty-Third Division of the Court of Appeals which reversed the Regional Trial Court's (RTC) ruling from 9 October 1995 favoring the petitioners.
- The appellate court declared spouses Elena and Rogelio Arciaga as the rightful owners of the disputed property.
Facts of the Case
- The property in question is a 911 square meter parcel of land located in Toril, Davao City, registered under Transfer Certificate of Title No. T-139473 in the name of Elena Arciaga.
- The land was part of the Y. Furukawa Daliao Plantation, previously administered by the National Abaca and Other Fibers Corporation (NAFCO) and the Board of Liquidators (BOL).
- Loreto Luga claimed to have occupied the land as a tenant since 1957, constructing a house there.
- An Occupant's Affidavit was executed in 1960 by Honorio Romero, a former NAFCO employee, pertaining to the landholding, which included the disputed parcel.
- In 1970 and 1972, Honorio transferred rights over portions of the land to Rogelio Arciaga.
- Elena applied for a patent/title to the land, leading to BOL's appro