Beo v. Court of Appeals
REITERATIONFacts
The Antecedents: Spouses Francisco and Felicisima Lianko owned five parcels of land. Felicisima inherited all five lots upon Francisco's death. She appointed her nephew, Dominador Abada, as administrator. Felicisima allegedly donated Lot No. 1661-D to her household helper, Dolores Buitre, and her two illegitimate children (petitioners), evidenced by a deed of donation dated November 15, 1950. The lots were unsurveyed at the time. In 1959, Felicisima caused a survey of her land with the consent of Dolores and Dominador. Private respondents claim this survey delineated Lot No. 1661-A, Lot No. 1661-C, Lot No. 1661-D, and Lot No. 1662 to Dominador Abada, and Lot No. 1663 to Dolores Buitre. Felicisima allegedly executed an affidavit on February 6, 1963, defining the boundaries of the lot donated to Dolores as Lot No. 1663. Petitioners claim the 1963 affidavit pertained to a separate donation of Lot No. 1663 to Dolores alone. They presented a certification that OCT No. 178 covering Lot No. 1663 was issued to Dolores Buitre. After Dolores' death, OCT No. 178 was cancelled and TCT No. 103 was issued in favor of petitioners. Petitioners purchased Lot No. 1661-D from Felicisima Lianko on November 23, 1973, for P10,000.00, to 'reinforce' their ownership, though it remained titled and declared in Felicisima's name. Petitioners claimed possession from 1950 to 1972. After the sale, Dominador Abada prevented Augusto Lianko from taking possession. Felicisima died intestate on March 31, 1976, and Dominador inherited her estate. Procedural History: Petitioners filed a complaint for possession and quieting of title over Lot No. 1661-D against Dominador Abada. Dominador died and was substituted by his wife and children. The Regional Trial Court (RTC) ruled in favor of petitioners, declaring them lawful owners and ordering private respondents to vacate. On appeal, the Court of Appeals (CA) reversed the RTC decision, finding that petitioners failed to satisfactorily prove that Lot No. 1661-D was the same land subject to the deed of donation and deed of sale. The Petition: Petitioners seek review of the CA decision, raising assignments of error concerning grave abuse of discretion amounting to lack of jurisdiction in ignoring the RTC's findings of fact, disregarding petitioners' evidence, and reversing the RTC decision.
Issue(s)
Whether the respondent Court of Appeals gravely abused its discretion amounting to lack of jurisdiction in ignoring the findings of fact of the Regional Trial Court, disregarding petitioners' oral and documentary evidence, and reversing and setting aside the appealed decision and declaring defendants-appellants the owners of the land in question. Whether Lot No. 1661-D was duly proved by petitioners to be the same land subject of the deed of donation and the deed of sale.
Ruling
The petition is denied, and the decision of the Court of Appeals dated May 9, 1990, is affirmed. The Supreme Court found that petitioners failed to prove the identity of the land in question.
Ratio Decidendi
On the issue of whether the respondent Court of Appeals gravely abused its discretion amounting to lack of jurisdiction in ignoring the findings of fact of the Regional Trial Court, disregarding petitioners' oral and documentary evidence, and reversing and setting aside the appealed decision and declaring defendants-appellants the owners of the land in question: The Court reiterated that findings of fact of the Court of Appeals, when supported by substantial evidence, are binding and conclusive and cannot be reviewed by the Supreme Court, as was the situation in this case. On the issue of whether Lot No. 1661-D was duly proved by petitioners to be the same land subject of the deed of donation and the deed of sale: The Supreme Court ruled in the negative. The Court found that the sketch plans presented by both parties showed significant discrepancies in the boundaries of Lot No. 1661-D when compared to the descriptions in the deed of donation and deed of sale. Specifically, the boundaries described in the sketch plans did not reconcile with those stated in the deeds. The appellate court correctly observed that such gross inconsistency led to the inescapable conclusion that the land described in the deeds did not pertain to Lot No. 1661-D as depicted in the sketch plans. The Court emphasized the invariable rule that a person claiming ownership of real property must clearly identify the land being claimed, in accordance with the title on which the right of ownership is anchored. Since the petitioners failed to explain the discrepancy or present other evidence to prove with certainty the location and area of the land they sought to recover, their action could not prosper. The basic rule requires proof of ownership coupled with the identity of the land. The Court further noted that the trial court's findings, which relied on the southern boundary and approximate land area, were weak and based on conjecture, failing to consider all boundaries. The appellate court's reversal was therefore justified based on the established jurisprudence that an action for recovery of possession requires the claimant to fully prove not only ownership but also the identity of the property claimed by describing its location, area, and boundaries. The incompatibility of the descriptions was too glaring to be ignored, leading to the conclusion that the property described in the deeds and the land in question could not be one and the same parcel. The Court also cited material inconsistencies such as the deed of sale containing the same old land description despite a later survey, the fact that only Lot No. 1663 was included in the extrajudicial settlement despite the possession of the deed of donation, and the four-year delay in taking formal action after the deed of sale, all of which militated against petitioners' claim of ownership.
Main Doctrine
A claimant seeking to recover possession of real property must prove not only ownership but also the exact identity of the property by clearly describing its location, area, and boundaries. Failure to establish the identity of the land renders the action for recovery of possession dismissible.