Case Summary (G.R. No. 199558)
Procedural Background and Trial Court Ruling
Petitioners Kawasa Magalang and Mona Wahab filed a complaint for recovery of possession and ownership and/or declaration of nullity of property acquisition, alleging that respondents fraudulently obtained titles over portions of Lot 1064 through falsified documents, displacing petitioners after they evacuated during the conflict in the early 1970s. The trial court ruled in favor of petitioners, ordering respondents to vacate the properties and declaring respondents’ titles and related documents null and void, except that dispossession of Lucibar Heretape would be subject to repayment of a loan. The trial court favored petitioners’ testimonies, rejected respondents’ documentary evidence as mere photocopies, and resolved that petitioners acquired ownership by prescription.
Respondents’ Position and Court of Appeals Decision
Respondents contended that titles were acquired lawfully, relying on original certificates of title (OCT) and older land registration proceedings. Respondents challenged the trial court’s assessment of documentary evidence and factual findings. The Court of Appeals reversed the trial court, ruling that petitioners failed to prove clear and convincing evidence of fraud, failed to establish ownership through prescription, and incorrectly discounted respondents’ originals of their Torrens titles. The Court of Appeals emphasized that Torrens titles are conclusive evidence of ownership and possession and that petitioners did not meet the burden of proof required to invalidate those titles or to establish superior ownership by prescription.
Issues on Appeal and Standards of Review
The principal issue was whether petitioners were entitled to reconveyance of the entire Lot 1064 or its subdivided portions based on allegations of fraud and prescription. The Supreme Court clarified that under Rule 45 of the Rules of Court, only questions of law are proper in a petition for review on certiorari, and factual findings of appellate courts are generally final when supported by substantial evidence. However, when appellate factual findings diverge from those of the trial court, as here, the Supreme Court may engage in independent factual determination.
Legal Basis for Action for Reconveyance
The Court analyzed that under Article 1456 of the New Civil Code, a person who obtains property through fraud holds it as a trustee of an implied trust for the benefit of the rightful owner. Therefore, a complaint for reconveyance aims to correct wrongful registration or acquisition of property by fraud, requiring the complainant to substantiate the claim of fraud with clear and convincing evidence. Article 434 further requires the complainant to identify the property and establish title by showing strength of claim rather than weakness of the adversary’s title.
Evaluation of Evidence and Findings on Ownership
The Court found that petitioners’ evidence—tax receipts, tax declarations, and general testimonies about cultivation and occupation—failed to overcome the conclusive presumption of ownership that Torrens titles confer on respondents. The Court emphasized that these titles, issued decades after the tax declarations and receipts, provide conclusive proof of ownership. The petitioners’ allegations of fraud were grounded in self-serving testimonies without corroborating clear and convincing evidence, insufficient under Philippine
...continue readingCase Syllabus (G.R. No. 199558)
Background and Parties Involved
- Petitioners Kawasa Magalang and Mona Wahab filed a complaint seeking recovery of possession and ownership, and/or declaration of nullity of acquisition of property against respondents Spouses Lucibar Heretape and Rosalina Funa, Roberto Landero, Spouses Nestor Heretape and Rosa Rogador, and Engr. Eusebio F. Fortinez.
- The property in dispute is Lot 1064, Pls-397-D, a 10-hectare land located in Salabaca, Ampatuan, Cotabato (now Daladap, Esperanza, Sultan Kudarat), later subdivided into three parts: Lot 1064-A, Lot 2238-A, and Lot 2238-B.
- The case was raffled to the Regional Trial Court (RTC), Branch 19, Isulan, Sultan Kudarat.
Facts and Contentions
- Petitioners claimed ownership of the entire 10-hectare lot, asserting it was inherited and occupied by Kawasa Magalang and his family, supported by tax declarations, tax receipts, and a 1969 memorandum of agreement to mortgage a 2.5-hectare portion to Lucibar Heretape.
- Petitioners alleged that during the 1970s, due to the Ilaga-Blackshirt conflict, they were forced to evacuate the land, and respondents usurped the entire property, subdivided it, and fraudulently obtained free patent titles through falsified documents with the aid of Engr. Eusebio Fortinez.
- Respondents answered that Kawasa Magalang misrepresented himself as owner; when he abandoned the lot, Pedro Deansin (also spelled Jansen), the rightful owner by transfer from Gomongon Batolawan, appeared and sold portions of the lot to respondents.
- Respondents claimed to have legally acquired titles from Pedro Deansin and have valid patents and Original Certificates of Title (OCT) for each subdivided lot: Lot 2238-B-owned by Lucibar Heretape; Lot 2238-A by Nestor Heretape; and Lot 1064-A by Roberto Landero.
- Respondents disputed petitioners' claims and emphasized their legal ownership under the Torrens system, supported by documentary evidence, though some documents were presented only as photocopies.
Evidence Presented
- Petitioners relied on:
- Testimony of Kawasa Magalang on inheritance and possession.
- Tax declarations and official receipts from the 1960s.
- A memorandum of agreement mortgaging part of the property.
- Witness testimonies to the effect of open cultivation and possession.
- Respondents relied on:
- Testimony that Pedro Deansin was the rightful owner who sold them portions.
- Documentary evidence, including deeds of sale and transfer, official decisions, and original certificates of title.
- Testimony from CENRO custodian who identified photocopied records related to the land.
- Petitioners' witnesses provided general testimony of cultivation and occupancy, but failed to provide specific acts of ownership or continuous, exclusive, and notorious possession for the period required by prescription.
Trial Court Decision
- The RTC ruled in favor of petitioners on October 3, 2003:
- Ordered respondents to vacate the lots and return possession to petitioners.
- Declared null and void respondents' deeds of transfer and original certificates of title.
- Directed respondents to surrender titles and reconv