Case Summary (G.R. No. 124605)
Background of Property and Family Relations
Dionisio Fontanilla was the original owner and possessor of a 12,508 square-meter parcel of land in Barangay Lucap, Alaminos, Pangasinan. In 1921, the land was declared under his name for taxation purposes and surveyed by Turner Land Surveying Company. The Bureau of Lands approved the survey plan in 1923. Due to failure to pay survey costs, Dionisio sold the land to his daughter Rosa in 1938 to prevent foreclosure. Rosa began paying property taxes in 1939. In 1955, Rosa sold the land via notarized but unregistered deed to her nephew, Santiago Fontanilla (one of the respondents). Respondents constructed a residential house on the land between 1955 and 1957. Rosa’s heirs later executed another deed of sale over the same land in favor of Santiago in 1957.
Petitioners’ Land Registration and Respondents’ Action
In 1978, during respondents’ absence from the Philippines, petitioners applied for land registration before the Land Registration Court of Pangasinan. Acting on their application, the court issued Original Certificate of Title No. 139 to petitioners in 1979. Respondents filed an action for reconveyance and annulment of the OCT in 1981, claiming ownership of the land. Petitioners asserted they purchased the property for P3,000 from Lorenza Fontanilla-Rasca (Amparo’s mother) and referenced an alleged deed of sale from Turner Land Surveying Company to Alberto Rasca (Amparo’s father), which they failed to present in court.
Trial Court Findings and Decision
The Regional Trial Court (RTC) adjudicated in favor of respondents, declaring them absolute and lawful owners of the land. The decision ordered petitioners to transfer OCT No. 139 back to respondents, pay attorney’s fees and exemplary damages, but did not grant moral damages. The RTC relied on the respondents’ continuous, open, and adverse possession of the property for over sixty years, including tax payments starting 1921 under Dionisio, 1939 under Rosa, and 1967 under respondents themselves. The court found petitioners’ claim based on the unpresented deed lacking in credibility.
Court of Appeals Affirmation
Both parties appealed to the Court of Appeals (CA). The CA affirmed the RTC’s ruling, maintaining respondents’ ownership. The CA refused petitioners’ contention that the judge who penned the decision was not the presiding judge during trial, citing jurisprudence that substitution of judges for decision writing does not invalidate findings when based on the trial transcript and does not violate due process.
Legal Principles on Factual Findings and Issues on Appeal
The Supreme Court emphasized that factual issues are not reviewable on a petition for certiorari, which raises only questions of law. Petitioner’s failure to present the deed to prove ownership raised a factual question conclusively resolved against them. Tax declarations, while not conclusive of ownership alone, coupled with adverse possession and payment of taxes over several decades, constitute strong evidence of ownership in Philippine jurisprudence.
Land Registration and Fraud Doctrine
The Court discussed the applicable laws governing registration of untitled lands under Act No. 496 (as amended) and Presidential Decree No. 1529 (Property Registration Decree). It held that registration judgments become final and incontestable after one year from entry of final decree unless annulled for fraud. Actual and extrinsic fraud, including intentional omission of facts and deprivation
...continue readingCase Syllabus (G.R. No. 124605)
Background and Facts of the Case
- Dionisio Fontanilla was the original owner and possessor of a 12,508 square meter parcel of land in Barangay Lucap, Alaminos, Pangasinan, declared in his name for taxation in 1921.
- Dionisio had four children: Rosa, Antonio, Jose, and Lorenza Fontanilla; the parties to the case are all first cousins related through these siblings.
- In 1921, the Turner Land Surveying Company surveyed the land with a conditional payment agreement, and the survey plan was approved by the Bureau of Lands in 1923.
- Dionisio sold the land to his daughter Rosa in 1938 due to failure to pay survey costs; Rosa began paying taxes in 1939.
- Rosa sold the land to her nephew Santiago Fontanilla in 1955 through a notarized but unregistered deed of absolute sale. Respondents built a strong, permanent house on the land between 1955 and 1957.
- Rosa's heirs executed another deed of absolute sale to Santiago in 1957, confirming the sale.
- Respondents left for the United States in 1978; during their absence, petitioners applied for and obtained a land registration and Original Certificate of Title (OCT) No. 139 in their names in 1979.
- Respondents filed an action for reconveyance and annulment of the OCT in 1981; the trial court decided in their favor in 1992.
- Both parties appealed to the Court of Appeals, which affirmed the trial court decision in 1995. The petitioners’ motion for reconsideration was denied in 1996, leading to the present Supreme Court review.
Issues Presented for Resolution
- Whether the decision of the Court of Appeals is supported by evidence.
- Whether the decision is in accordance with the law and jurisprudence.
Court’s Analysis on Factual Issues
- The question of factual sufficiency is not subject to review by the Supreme Court on appeal by certiorari; only legal questions are open for review.
- The fact that the judge who penned the decision on the case was not the one who presided during the trial does not render the decision void as per established jurisprudence.
- Petitioners failed to present the deed of sale by Turner Land Surveying Company to Alberto Rasca, which they relied on to claim ownership.
- Respondents have demonstrated open, continuous, and adverse possession of the land for more than 60 years, with continuity from Dionisio Fontanil