Golingco v. Peña
REITERATIONFacts
The Antecedents: Plaintiffs-appellants (hereinafter referred to as appellants) sold a portion of their property to the defendant-appellee (hereinafter referred to as appellee). The dispute arose concerning the exact area of land sold and the appellee's possession thereof. Procedural History: The case originated from the Court of First Instance of Albay, which appointed a Commissioner for the relocation of specific parcels of land. The appellants appealed the lower court's order approving the Commissioner's report to the Court of Appeals. The Court of Appeals certified the case to the Supreme Court due to the purely legal nature of the issues involved. The Appeal: The appellants contended that the Commissioner should have determined and stated the area of land actually occupied by the appellee in his report. They argued that the execution of the revived judgment should strictly conform to the sale, which they claimed was only for 16 hectares. Since the Commissioner failed to specify the area occupied, they argued the lower court should not have approved the report.
Issue(s)
Whether the Commissioner's report on the relocation of parcels of land was validly approved despite not stating the exact area occupied by the appellee. Whether the execution of the judgment should be strictly limited to the specific area claimed to have been sold, irrespective of the appellee's actual possession and prior admissions.
Ruling
The Supreme Court affirmed the order of the lower court approving the Commissioner's report. The Court found no merit in the appellants' contention and considered the relocation sufficient for its intended purpose.
Ratio Decidendi
On the issue of the Commissioner's report and the stated area: The Court held that it was unnecessary for the Commissioner's report to state the exact area of the land in hectares. The relocation was conducted on the parcels of land that were actually in the possession of the appellee at the time. The Court reasoned that the purpose of the relocation was to prevent any encroachment by the appellee upon the remaining lands of the appellants, and the relocation as made was sufficient to achieve this objective. The decision of the lower court was also silent on the specific area, and the parties had submitted a joint petition recognizing the appellee's possession and ownership as alleged in the complaint and admitted in the answer. On the issue of strict adherence to the claimed sale area: The Court found the appellants' contention that they sold only 16 hectares to be without merit in the context of the proceedings. While they claimed this in their answer, the lower court's decision did not specify the area. More importantly, the appellants had expressly recognized the appellee's possession and ownership of the lands in a joint petition submitted to the court. This recognition, coupled with the fact that the relocation was based on the appellee's actual possession, rendered the appellants' argument regarding the precise area sold moot for the purpose of the relocation and execution of the judgment.
Main Doctrine
The Supreme Court affirmed the order approving a relocation survey report, holding that it was unnecessary for the commissioner to state the exact area of the land in the report, as the relocation was made on the lands actually in the possession of the appellee. The Court emphasized that the parties' admissions in their pleadings regarding possession and ownership were controlling, and the relocation served its purpose of preventing encroachment on the remaining lands of the appellants.