New Testament Church of God v. Court of Appeals
REITERATIONFacts
The Antecedents: Respondent Laureano Lucas was issued Homestead Patent No. 63351 and Sales Patent No. V-392, covering parcels of land in Cauayan, Isabela, with corresponding Original Certificates of Title (OCT) issued in his name. Petitioner purchased a parcel of land from spouses Fausto Atienza and Cleopatra L. Ordonez, which was covered by OCT No. P-1252, previously acquired by the Ordonez couple through a homestead patent. Petitioner's title (TCT No. 7836) was issued after cancellation of OCT No. P-1252. Procedural History: Private respondents sought the annulment of petitioner's title, claiming that portions of their lands covered by their patents were included in the homestead patent of petitioner's predecessors-in-interest. The Regional Trial Court (RTC) ruled in favor of private respondents, declaring them lawful owners of the lands covered by their OCTs and petitioner's TCT No. T-7836 null and void insofar as it overlapped with the private respondents' titles. The Court of Appeals (CA) affirmed the RTC decision. Petitioner's motion for reconsideration was denied. The Petition: Petitioner filed a petition for certiorari with the Supreme Court, seeking to set aside the decision of the Court of Appeals.
Issue(s)
Whether petitioner's lands overlap the lands of private respondents. Whether the Court of Appeals committed a reversible error of law in affirming the RTC's decision based on the evidence presented.
Ruling
The petition is DENIED. The decision of the Court of Appeals affirming the Regional Trial Court's decision is upheld.
Ratio Decidendi
On the issue of overlapping titles and the Court of Appeals' findings: The Court reiterated the principle that in civil cases, the party with the burden of proof must establish their case by a preponderance of evidence. Private respondents presented three geodetic engineers to testify on the issue of overlapping titles, and their findings were supported by testimonial and documentary evidence. Petitioner failed to present any witness to rebut these findings. The argument that the geodetic engineers would naturally testify in favor of private respondents because they were hired by them was dismissed, especially since two of them were officials of the Bureau of Lands, and the disputable presumption that official duties have been regularly performed was not rebutted. Suspicion and conjectures cannot overcome this presumption in the absence of contrary proof. Therefore, the Court of Appeals' decision was based on substantial evidence on record. On the scope of review in a petition for certiorari under Rule 45: The Court emphasized that in a petition for certiorari under Rule 45 of the Revised Rules of Court, it reviews only errors of law committed by the Court of Appeals. It is not the function of the Supreme Court to re-examine the evidence submitted by the parties unless the findings of fact of the Court of Appeals are not supported by the evidence on record or the judgment is based on a misapprehension of facts. In this case, the findings of fact of the Court of Appeals were supported by the evidence, and no reversible error of law was committed.
Main Doctrine
In a petition for certiorari under Rule 45, the Supreme Court reviews only errors of law, not errors of fact, unless the findings of the Court of Appeals are not supported by evidence or are based on a misapprehension of facts. The burden of proof in civil cases rests on the party with the affirmative of the issue, who must establish their case by a preponderance of evidence.