Case Summary (G.R. No. 108558)
Applicable Law and Proceedings
The appeal is brought under Rule 45 of the Rules of Court, contesting the decisions of the Court of Appeals dated July 29, 1992 and January 14, 1993, which affirmed the ruling of the Regional Trial Court that established the ownership of the land in favor of the private respondents. The primary legal focus is on the evidence of possession and ownership of the land, including the evaluation of tax declarations and testimonial evidence.
Factual Background
The factual backdrop reveals that the private respondents presented substantial evidence demonstrating their ownership of the property, including ancient tax declarations and a deed of donation dated September 24, 1923. In contrast, the petitioners relied on scant documentation, primarily claiming succession through the family of Ignacio Montes, which lacked corroboration. The trial court emphasized the long-standing and uninterrupted possession of the land by the heirs of Esteban Abad.
Trial Court’s Conclusion
The trial court concluded that the evidence presented by the private respondents overwhelmingly supported their claim to the property. Testimony from Atty. Jose Gonzales, while a counsel for the private respondents, was deemed credible as he had direct knowledge of the ownership and occupancy of the land, having owned adjacent property.
Ruling of the Court of Appeals
The Court of Appeals reiterated that distinct weight is afforded to the factual conclusions of the trial and appellate courts unless proven arbitrary. They upheld the trial court's judgment affirming the private respondents' ownership based on the tax declarations, continuous possession, and the validity of the ancient deed of donation. The Court found that the petitioners’ claims were not substantiated.
Issues Raised by Petitioners
Petitioners asserted multiple issues, including the alleged contradiction of evidence regarding private respondents' ownership and possession, the questioned validity of the Deed of Donation executed, and the claim that private respondents did not establish their ownership through actual possession. They contended that the trial court exhibited grave abuse of discretion when affirming the legitimacy of the Deed of Donation.
Analysis of Ownership Claims
The core issue addressed was the claim of ownership over the property. The ruling emphasized that mere physical possession by the petitioners did not equate to legal ownership. The Court concluded that private respondents' established possession and consistent payment of land taxes substantiated their ownership claim.
Validity of Deed of Donation
The petitioners' challenge to the Deed of Donation was dismissed based on the doctrine of laches. Despite the claim that the Deed was invalid due to the alleged deceased nature of Maria Montes at the time of execution, the Court noted that challenging such documents decades later was not permissible. Moreover, the evidence presented
...continue readingCase Syllabus (G.R. No. 108558)
Introduction
- This syllabus pertains to the case of Andrea Tabuso and Renato Bismorte vs. Court of Appeals and the Heirs of Esteban Abad, which was decided by the Supreme Court of the Philippines on June 21, 2001.
- The case revolves around the issue of ownership of an unregistered parcel of land located in Antipolo, Naval, Leyte.
Statement of the Case
- The petitioners, Andrea Tabuso and Renato Bismorte, appealed under Rule 45 of the Rules of Court against the July 29, 1992 Decision of the Court of Appeals (CA) in CA-GR CV No. 26047.
- The CA affirmed the ruling of the Regional Trial Court (RTC), which recognized the ownership of the land by the private respondents, the heirs of Esteban Abad.
- The CA's decision included the directive that costs be borne by the petitioners.
Facts of the Case
The case involves a declaration of ownership over a parcel of land measuring 3,267 square meters.
Evidence presented by the petitioners included:
- A tax declaration from 1912 in the name of Ignacio Montes, with tax payments made only in 1981.
- Tabuso claimed ownership as a successor in interest to Andrea Elaba, who is related to Ignacio Montes.
- The defendants (heirs of Esteban Abad) had possession of the property, and a house on the land was built by Marcelo Tabuso, the father of Andrea Tabuso.
The defendants' evidence included:
- A document showing the land was donated to Isabel Elaba in 1923, who sold it to Esteban Abad in 1948.
- Subsequent tax declarations reflecting ownership changes and continuous tax payments from 1947 to 1982.
- The land was tenanted u