Case Summary (G.R. No. 254564)
Background of the Case
The case centers on the ownership and possession rights over Pitogo Island, specifically Lot Nos. 6972 and 6973, with Lot No. 6973 being titled under Katibayan ng Orihinal na Titulo Bilang 35669 issued to the heirs of Mario Padayao. Dante Padayao, representing the heirs, faced eviction from the island based on a letter from the Provincial Government declaring it a protected area. This eviction escalated to a conflicting situation, leading to a demolition of structures on the island, which prompted legal action by Dante Padayao.
Factual Developments
Following a letter from the Provincial Government mandating the residents to vacate Pitogo Island, armed groups, including some respondents, executed the eviction forcefully. Dante Padayao’s legal representation argued that the land belonged to his family through historic occupation and tax payments, which were substantiated through testimonies and forensic documents demonstrating his predecessors’ possession since 1920, inclusive of a survey plan from 1934.
Initial Ruling by the Regional Trial Court
The Regional Trial Court had favored Dante Padayao in a decision that required the respondents and their affiliates to vacate Lot Nos. 6972 and 6973, arguing that the evidence strongly favored the Padayaos as rightful claimants and highlighting the lack of merit in the respondents’ claims of environmental protection justifying the demolition.
Court of Appeals' Position
Upon appeal, the Court of Appeals affirmed the lower court's ruling but limited the reversion to Lot No. 6973 only. The appellate court reasoned that Dante had verifiable ownership over Lot No. 6973 but had not demonstrated adequate proof of ownership for Lot No. 6972, which was presumed to be public land due to his failure to provide sufficient documentation supporting his claim.
Issues of Legal Jurisdiction
While the jurisdiction for the case remained with the Regional Trial Court, it was raised that the necessary evidence to establish the court’s jurisdiction based on the value of the properties claimed was absent from the original complaint. However, the Supreme Court determined that since the respondents did not contest this jurisdiction during the proceedings, they were estopped from doing so later.
Supreme Court's Decision
The Supreme Court recognized that Dante Padayao holds a superior right of possession over both Lot Nos. 6972 and 6973. The Court specified that the classifications supporting the land as alienable and disposable applied equally to Lot No. 6972, reinforcing Dante’s historical claims
...continue readingCase Syllabus (G.R. No. 254564)
Parties and Procedural History
- Petitioner: Punong Barangay Dante Padayao (Dante), seeking recovery of possession and damages.
- Respondents: Gov. Luis Raymund F. Villafuerte, Jr., Atty. Janis Ian Regaspi-Cleofe, Jose Francisco L. Musa, Jr., Luis Zulueta, Jovie Villareal, Dondon Obias, and Provincial Government of Camarines Sur.
- Case filed in Regional Trial Court (RTC) of San Jose, Camarines Sur, Civil Case No. T-1133.
- RTC ruled in favor of Dante, ordering respondents to vacate and restore possession of Pitogo Island.
- Court of Appeals (CA) affirmed RTC decision with modification, limiting possession restoration to Lot No. 6973 covered by KOT Blg. 35669.
- Petition for Review on Certiorari filed by Dante before the Supreme Court.
Subject Matter and Property Details
- The case concerns possession and ownership issues over Pitogo Island, Caramoan, Camarines Sur.
- Property consists of Lot Nos. 6972 and 6973.
- Lot No. 6973 is covered by Katibayan ng Orihinal na Titulo Bilang 35669 (KOT Blg. 35669) issued to the Heirs of Mario Padayao, represented by Dante.
- Total area covered by KOT Blg. 35669 is 74,407 sqm.
Facts and Background
- In 2009, the Provincial Government issued a letter requiring residents including Rowel Padayao to vacate Pitogo Island, citing it as a protected area and danger zone.
- Armed men accompanied respondents in informing residents to vacate or face demolition of structures.
- Demolition of houses on Pitogo Island, including Dante's, took place on February 4, 2009.
- Dante asserted ownership via continuous possession of the land since 1920 and through documentary evidence including survey plan and tax payments.
- DENR and Bureau of Forestry certifications indicated Pitogo Island is alienable and disposable, not a protected area.
- Respondents argued the island’s protected area status and environmental threat justified relocation and demolition.
Petitioner’s Evidence and Arguments
- Continuous and adverse possession since 1920, supported by tax payments from 1945 to 2009.
- Presentation of Survey Plan (December 6, 1934) for Juliao Padayao covering lot numbers.
- Certification from DENR and Land Classification Map 882 (1931) confirming alienable and disposable status of Pitogo Island.
- Testimony that demolition was arbitrary and without proper authority or due process.
- Asserti