Case Summary (G.R. No. 139603)
Petitioner and Respondent
Petitioner: Conchita Quinao
Respondents: The People of the Philippines, represented by the Office of the Solicitor General, and private complainant Francisco F. Del Monte
Key Dates
– February 2, 1993: Alleged forcible entry, collection of 12,000 coconuts, conversion to copra, and sale for ₱14,580
– January 25, 1993: Issuance of Tax Declaration No. 1195 in favor of Lorenzo Cases Leoniso (basis for petitioners’ claim)
– January 14, 1999: Court of Appeals decision affirming RTC conviction
– June 30, 1999: CA resolution denying reconsideration
– July 14, 2000: Supreme Court decision
Applicable Law
1987 Constitution; Article 312 of the Revised Penal Code (usurpation of real property or usurpation of real rights in property by means of violence or intimidation with intent to gain).
Factual Background and Civil Title Dispute
Private complainant established prior adjudication of the land in Civil Case No. 3561 in favor of his predecessors‐in‐interest, evidenced by Tax Declaration No. 1202 (canceling Tax Declaration No. 18612). Petitioner relied on Tax Declaration No. 1195, claiming the property as part of her grandfather’s inheritance. Boundaries and area were contested but overlapped with those previously awarded to complainant’s predecessor.
Commissioner's Findings
Pursuant to a court‐appointed commission, Deputy Sheriff Anacta confirmed via site inspection and sketch map that the area claimed by petitioner encroached upon complainant’s legally adjudicated parcel, as ordered by the trial court on February 1, 1994.
Trial Court Proceedings and Judgment
At trial, both sides presented boundary witnesses. Prosecution witness Bienvenido Del Monte testified to forcible entry, use of violence and threats, and immediate harvesting of coconuts. The Regional Trial Court found all elements of usurpation proven—occupation of another’s property by violence or intimidation with intent to gain—and sentenced petitioners jointly and severally to a fine of ₱174,960 (equivalent to proceeds for nearly three years at ₱14,580 per quarter). The court enjoined further intrusion and ordered police assistance to secure complainant’s possession.
Court of Appeals Ruling
The Court of Appeals, in CA-G.R. CR No. 19412, affirmed the RTC’s factual findings on title, violence, intimidation, and intent to gain. It adopted the commissioner’s sketch and reiterated that the issue of ownership had been conclusively settled in Civil Case No. 3561. The petition for reconsideration was denied.
Issues Raised on Supreme Court Review
- Whether an elderly female petitioner could be held liable for usurpation based on alleged conspiracy supported merely by speculation.
- Whether subsequent use of force and intimidation sufficed to establish usurpation.
- Whether one claiming ownership could be convicted of usurpation of her own property.
Supreme Court Analysis: Ownership
The Court held that ownership was conclusively determined by the prior civil judgment. Petitioner’s reliance on Tax Declaration No. 1195 was insufficient to disturb the earlier adjudication. The c
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Facts of the Case
- On February 2, 1993, at around 9:00 a.m., Conchita Quinao and Salvador Cases entered agricultural land at Sitio Bagacay, Brgy. Potong, Lapinig, Northern Samar.
- Private complainant Francisco F. Del Monte owned the property by virtue of Tax Declaration No. 1202, successor to Civil Case No. 3561 award.
- Accused gathered 12,000 coconuts, converted them into copra, and sold same for P14,580.00, to the prejudice of Del Monte.
- Bienvenido Delmonte testified that the accused used force and intimidation, and threatened the occupants, who requested police assistance.
- Quinao and Cases claimed ownership under Tax Declaration No. 1195 in the name of their grandfather, Lorenzo Cases Leoniso, asserting a separate six-hectare parcel with distinct boundaries.
Procedural History
- Information for Usurpation of Real Property under Article 312, RPC, filed in RTC, Laoang, Northern Samar (Branch 21).
- Both accused pleaded not guilty; trial court conducted evidence‐in‐chief and defense presentations.
- RTC rendered judgment convicting both defendants, imposing a fine of P174,960.00 and injunctive relief in favor of Del Monte, ordering police assistance.
- Salvador Cases died April 9, 1995; his death noted on September 25, 1997.
- Conchita Quinao appealed to the Court of Appeals (CA-G.R. CR No. 19412); CA affirmed both the conviction and denial of her motion for reconsideration.
- Petitioner elevated case to the Supreme Court via petition for review on certiorari under Rule 45.
Issues Presented
- Whether an elderly female accused could be