Mejia v. Intermediate Appellate Court
REITERATIONFacts
1. The Antecedents: The underlying dispute concerns the ownership and possession of a parcel of land. Private respondents, the Spouses Juan P. Velasco and Carmen F. Velasco, filed an action to quiet title against petitioner, Marcelino Mejia. The trial court found that the private respondents were the true and lawful owners of a 483 square meter portion of the property located in Barrio San Isidro Sur, Binmaley, Pangasinan, and ordered the petitioner to vacate the premises and restore possession to the private respondents. The court also awarded actual damages, attorney's fees, and litigation expenses to the private respondents, while dismissing the petitioner's counterclaim. 2. Procedural History: The Spouses Juan P. Velasco and Carmen F. Velasco initiated an action for quieting of title against Marcelino Mejia before the Court of First Instance of Pangasinan, docketed as Civil Case No. 15448. Following a trial, the court rendered a decision in favor of the plaintiffs. The petitioner, as the defendant in the trial court, appealed this decision to the Court of Appeals. The appellate court affirmed the decision of the trial court. Subsequently, the petitioner's motion for reconsideration of the appellate court's decision was denied. This petition for review on certiorari is filed to challenge the decision of the Court of Appeals. 3. The Petition: The petitioner seeks review on certiorari of the decision of the Court of Appeals, arguing that the appellate court committed grave and reversible error. Specifically, the petitioner contends that the appellate court erred in affirming the trial court's award of the entire parcel of land to the private respondents, when the private respondents' claim was limited to a 483 square meter portion. Furthermore, the petitioner argues that the private respondents failed to present satisfactory evidence to support the award of damages. The petition challenges the scope of the property awarded and the evidentiary basis for the damages granted by the lower courts.
Issue(s)
Whether the appellate court erred in affirming the trial court's award of the entire parcel of land to the private respondents. Whether the private respondents adduced satisfactory evidence to warrant the award of damages.
Ruling
The petition is DENIED. The assailed appellate court decision is AFFIRMED, with a modification regarding the award of damages.
Ratio Decidendi
On the issue of ownership and award of the entire parcel: The Court found that the decision of the court a quo, as affirmed by the appellate court, clearly declared private respondents as owners of the property in question with an area of 483 square meters, more or less. The records showed that Juan P. Velasco acquired the 483 square meter portion from Rafael de los Santos, which was distinct from the 953 square meter portion acquired by the petitioner from his mother, Carmen de los Santos. Therefore, the contention that private respondents were declared owners of more than what they prayed for was unsubstantiated, as the lower courts correctly identified and awarded the specific 483 square meter portion claimed by the private respondents. The factual findings of the trial court, affirmed by the Court of Appeals, are binding on the Supreme Court in the absence of grave abuse of discretion or reversible error. On the issue of damages: The Court found the award of damages to be proper and reasonable. The trial court found that the fishpond portion of the land did not produce income for the private respondents due to the acts of the petitioner, who admitted possession of the same. The actual damages of P2,130.00 were awarded for unearned income from February 1975 to November 1978 (2 years and 8 months) at P800.00 annually. Considering the petitioner's attitude and the dilatory nature of the appeal, the Court deemed it just to order the petitioner to pay P800.00 annually from February 1975 until actual vacation and restoration of possession, with legal interest.
Main Doctrine
The Court affirmed the appellate court's decision declaring private respondents as the lawful owners of a specific portion of the property and ordering the petitioner to vacate and pay damages, finding no grave abuse of discretion in the lower courts' factual findings and application of law.