Fuentes v. Uy
REITERATIONFacts
The Antecedents: Petitioner Maximino Fuentes and private respondents Virgilio Uy, et al. are owners of adjoining parcels of land. A dispute arose concerning a 411-square meter portion of land, which petitioner alleged was forcibly taken and entered by the private respondents. Relocation surveys were conducted by engineers, both before and after the filing of the case. Procedural History: The Metropolitan Court of Clarin-Tudela (MCTC) found that the private respondents had superior evidence and had not committed forcible dispossession, ruling that the disputed area belonged to Virgilio Uy. The Regional Trial Court (RTC) affirmed the MCTC decision, deleting only the monetary award. The Court of Appeals (CA) also affirmed the RTC's decision. The Petition: Petitioner filed a petition for review with the Supreme Court, raising the same errors assigned before the CA, essentially questioning whether the lower courts erred in finding that there was no forcible entry and that the private respondents did not commit acts constituting forcible entry. The consolidated issue presented was who had actual, physical, and prior possession of the disputed portion.
Issue(s)
Whether the Regional Trial Court gravely erred in deciding that the petitioner had no evidence to support the allegation that the private respondents entered the portion in question by force and intimidation, and whether the Regional Trial Court erred in sustaining that the private respondents did not commit any act constituting forcible entry. Who is in actual, physical, and prior possession of the portion in question?
Ruling
The petition for review is unmeritorious and is hereby DISMISSED for utter lack of merit. Double costs against petitioner.
Ratio Decidendi
On the issue of whether the RTC gravely erred in deciding that the petitioner had no evidence to support the allegation of forcible entry and intimidation, and whether the RTC erred in sustaining that the private respondents did not commit any act constituting forcible entry: The Supreme Court reiterated the oft-stated doctrine that factual findings of the Court of Appeals affirming those of the trial court are binding on the Supreme Court unless there is a clear showing that such findings are tainted with arbitrariness, capriciousness, or palpable error. The Court found that the petitioner failed to demonstrate any of the exceptions that would justify a review of the factual findings of the Court of Appeals. The findings and conclusions of the MCTC, RTC, and CA regarding the issue of possession were consistent and supported by the evidence on record. The trial court noted that the petitioner did not question the improvements made by the private respondents on the dike for many years, only initiating action in 1987, which prompted relocation surveys. The Court found no error in the lower courts' determination that there was no forcible dispossession and that the disputed area belonged to private respondent Virgilio Uy. On the issue of who is in actual, physical, and prior possession of the portion in question: The Supreme Court held that the question of who has prior actual possession over a contested portion of land is patently a question of fact. A petition for review under Rule 45 of the Rules of Court is limited to questions of law. Since the petitioner failed to show any reversible error committed by the respondent Court of Appeals, and the factual findings of the lower courts were consistent and supported by evidence, the Supreme Court found no reason to disturb such findings. The Court emphasized that prevailing jurisprudence uniformly holds that findings of fact of the trial court, particularly when affirmed by the Court of Appeals, are binding upon the Supreme Court.
Main Doctrine
Factual findings of the Court of Appeals affirming those of the trial court are binding on the Supreme Court unless there is a clear showing of arbitrariness, capriciousness, or palpable error. A petition for review under Rule 45 is limited to questions of law, and the issue of prior actual possession is a question of fact beyond its purview.