Heirs of Borlado v. Court of Appeals
REITERATIONFacts
The Antecedents: The heirs of Simeon Borlado (petitioners) claimed ownership over Lot No. 2097 based on their ancestor Serapio Borlado. Serapio had sold the lot to Francisco Bacero on April 15, 1942. Francisco's widow, Amparo Dionisio Vda. de Bacero, sold the lot to spouses Bienvenido Bulan and Salvacion Borbon on August 27, 1954. The Bulans had been in actual possession of the lot since December 1947 due to a loan granted by them to Francisco Bacero. Salvacion Borbon Vda. de Bulan declared the lot in her name for taxation purposes and paid the corresponding taxes. The Bulans' possession was continuous, peaceful, uninterrupted, adverse, and exclusive until November 4, 1972, when petitioners forcibly entered and took possession. Procedural History: On November 23, 1972, respondents filed an ejectment case against petitioners, which was decided in favor of respondents by the Municipal Court. Petitioners were ordered to vacate the lot, deliver possession, and pay 100 cavans of palay annually from 1972, plus attorney's fees and costs. Instead of appealing, petitioners filed a new case with the Regional Trial Court (RTC) for declaration of ownership and recovery of possession. The RTC dismissed petitioners' complaint for lack of cause of action and affirmed the dispositive portion of the Municipal Court's decision, with modifications regarding the award of damages. The Court of Appeals affirmed the RTC decision in toto. The Petition: The heirs of Simeon Borlado filed a petition for certiorari with the Supreme Court, questioning the Court of Appeals' ruling that respondents were the owners of the lot.
Issue(s)
Whether the Court of Appeals erred in ruling that respondents were the owners of the lot in question. Whether the award of 100 cavans of palay annually as damages is valid.
Ruling
The Supreme Court denied the petition and affirmed the decision of the Court of Appeals, with the modification that the award of 100 cavans of palay annually as damages was deleted.
Ratio Decidendi
On the issue of ownership and the Court of Appeals' findings of fact: The Supreme Court held that it cannot review the findings of fact of the Court of Appeals when such findings are supported by substantial evidence. The Court emphasized that it is not a trier of facts and its function is not to re-evaluate the probative value of evidence presented. Since the petitioners failed to demonstrate that their case fell under any of the exceptions to the rule on non-reviewability of factual findings, the findings of the Court of Appeals were deemed conclusive and binding. The Court reiterated that questions of fact cannot be raised in an appeal via certiorari before the Supreme Court. On the award of 100 cavans of palay annually as damages: The Supreme Court ruled that the trial court and the Court of Appeals erred in holding petitioners liable to pay respondents 100 cavans of palay every year from 1972 until they vacated the premises. The Court explained that 'palay' is not legal tender currency in the Philippines, and therefore, such an award cannot be sustained as a form of damages. Damages must be quantifiable in legal tender. This modification was made as a matter of law, irrespective of the factual findings on ownership.
Main Doctrine
The Supreme Court may not review findings of fact of the Court of Appeals when supported by substantial evidence, unless the case falls under exceptions. Awards of damages must be based on legal tender.