People v. Court of Appeals
REITERATIONFacts
The Antecedents: This case originated from cadastral proceedings initiated by the Director of Lands concerning Lot No. 10739, a parcel of riceland in Oas, Albay, with an area of 10,775 square meters. Romeo Divinaflor claimed ownership of this lot, asserting possession in the concept of owner for over thirty years. The trial court found that Divinaflor, along with his predecessor-in-interest, had possessed the land openly, continuously, adversely, notoriously, and exclusively since 1939, which predated the legal requirement of June 12, 1945. The land was originally owned by Marcial Listana, who possessed it since 1939, and Divinaflor acquired ownership through a deed of absolute sale on May 21, 1973. Procedural History: The Director of Lands initiated cadastral proceedings for Lot No. 10739. Romeo Divinaflor filed an answer claiming ownership. After a general default order, Divinaflor presented evidence, and the Regional Trial Court of Ligao, Albay, Branch 12, ordered the registration and confirmation of the lot in the names of Romeo Divinaflor and his wife. The Director of Lands appealed to the Court of Appeals, arguing that Divinaflor's evidence of possession since 1939 was insufficient, citing the earliest tax declaration in 1980 and tax payment in 1990. The Court of Appeals affirmed the trial court's decision, holding that proof of open, continuous, peaceful, and adverse possession was sufficiently established by Divinaflor's testimony, and that tax declarations were not strictly necessary. The Petition: The Director of Lands filed a petition for review on certiorari under Rule 45 of the Rules of Court, seeking to reverse the Court of Appeals' decision. The sole issue raised was whether Romeo Divinaflor had acquired registrable title over the subject property. The petitioner argued that Divinaflor failed to adduce sufficient evidence of possession since June 12, 1945, contending that Divinaflor's predecessor-in-interest, Marcial Listana, did not sufficiently prove possession since 1939, and that Divinaflor was incompetent to testify on his predecessor's possession as he was born in 1941. The Supreme Court denied the petition, affirming the lower courts' findings, and reiterated that its review under Rule 45 is limited to errors of law, not fact, and that the credibility of witnesses and the sufficiency of evidence are factual matters already resolved by the lower courts.
Issue(s)
Whether or not the respondent has acquired registrable title over the subject property. Whether or not the factual findings of the lower courts, affirmed by the Court of Appeals, may be reviewed by the Supreme Court in a petition for review on certiorari under Rule 45 of the Rules of Court. Whether or not the testimony of claimant Romeo Divinaflor regarding his predecessor-in-interest's possession since 1939 is credible and competent. Whether or not the belated declaration of the property for tax purposes negates the fact of possession since June 12, 1945.
Ruling
The Supreme Court denied the petition for review on certiorari for lack of merit and affirmed the decision of the Court of Appeals, which sustained the Regional Trial Court's judgment granting the registration and confirmation of Lot No. 10739 in the name of Spouses Romeo Divinaflor and Nenita Radan.
Ratio Decidendi
On Issue 1: The Supreme Court found no reversible error in the assailed judgment, upholding the well-entrenched doctrine that factual findings of the trial court, when affirmed by the Court of Appeals, are conclusive and generally not subject to review. While the petitioner framed the issue as an error of law regarding registrable title, the arguments essentially called for a re-evaluation of the evidence, which is outside the scope of a petition for review on certiorari under Rule 45 of the Rules of Court. The Court emphasized that it is not its function to analyze and weigh all over again the evidence, testimonial and evidentiary, adduced by the parties, particularly where the findings of both the trial court and the appellate court on the matter coincide. The Court concluded that no compelling reasons were adduced to deviate from the lower courts' concurrent findings that Divinaflor and his predecessor had satisfactorily possessed the land since 1939, thus meeting the "since June 12, 1945 or earlier" requirement for judicial confirmation of imperfect title under Section 48(b) of Commonwealth Act No. 141 (Public Land Act), as amended. On Issue 2: The Supreme Court reiterated that its jurisdiction in petitions for review on certiorari under Rule 45 of the Rules of Court is strictly limited to the review and revision of errors of law allegedly committed by the appellate court, as its findings of fact are deemed conclusive. Petitioner's arguments directly contravened this rule by asking the Court to re-examine the evidentiary basis of the lower courts' findings. The Court cited De la Cruz vs. Court of Appeals (1996) to underscore that it is not a trier of facts. Moreover, as held in South Sea Surety and Insurance Co., Inc. vs. Court of Appeals (1995), it is not the function of the Supreme Court to assess and evaluate all over again the evidence, testimonial and evidentiary, adduced by the parties, particularly where the findings of both the trial court and the appellate court on the matter coincide. This procedural principle is fundamental in maintaining the hierarchical structure of judicial review and respecting the fact-finding prerogatives of lower courts. On Issue 3: The Court rejected the petitioner's challenge to the credibility and competency of claimant Divinaflor's testimony regarding his predecessor-in-interest's possession since 1939. Firstly, issues of credibility are best determined by the trial judge, who has the unique opportunity to personally hear the witnesses testify and observe their deportment and manner of testifying, a principle affirmed in Jarco Marketing Corporation vs. Court of Appeals (1999) and Abalos vs. Court of Appeals (1999). Both the trial court and the Court of Appeals found Divinaflor's testimony convincing. Secondly, concerning the alleged incompetency of Divinaflor due to his age, the petitioner failed to interpose a timely objection on this ground at any stage of the proceedings, resulting in a waiver of any objection to the admissibility of such testimony, as established in Chua vs. Court of Appeals (1999). Even if timely objected to, a person is competent to be a witness if capable of perceiving at the time of the occurrence of the fact and making that perception known. The Court noted that Divinaflor, born in 1941, was four years old in 1945 and grew up in the same barrio, having seen Marcial Listana possessing the land. The Court applied the rule that a child, regardless of age, can be a competent witness if they possess the capacity of observation, recollection, and communication, as reiterated in People vs. Nang (1998). On Issue 4: The Supreme Court affirmed the Court of Appeals' ruling that the belated declaration of the property for tax purposes does not necessarily lead to the conclusion that the predecessors were not in possession of the land as required by law since 1945. While the Court has consistently held that tax declarations or tax receipts are good indicia of possession in the concept of an owner, as seen in Director of Lands vs. Court of Appeals (supra) and Republic vs. Court of Appeals (1996), it does not automatically follow that belated declaration for tax purposes negates the fact of possession. The Court referenced Viernes, et al. vs. Agpaoa (1921) and Director of Lands vs. Court of Appeals (1984) to emphasize that the mere payment of taxes does not confer or prove ownership. Furthermore, the omission to declare land for taxation at the inception of the tax system does not destroy continuous and adverse possession under claim of ownership, a principle upheld in Fontanilla vs. Director of Lands, et al. (1952). In this specific case, the continuous possession, corroborated by testimony and the absence of other claimants, was deemed sufficient to establish the required length of possession under the law, notwithstanding the late tax declarations.
Main Doctrine
The Supreme Court affirmed the decision of the Court of Appeals, upholding the registration and confirmation of Lot No. 10739 in favor of Romeo Divinaflor. The Court reiterated that the determination of open, continuous, exclusive, and notorious possession under a bona fide claim of ownership since June 12, 1945, or earlier, is a question of fact, and the findings of the trial court, affirmed by the appellate court, are conclusive. The Court also clarified issues regarding witness competency and the evidentiary value of tax declarations.