Heirs of Francisco Nabong v. Añar
REITERATIONFacts
The Antecedents This case originated from a complaint for Quieting of Title with Damages filed by the petitioners, the heirs of Francisco Nabong, against the respondents, the heirs of Apolonio Añar. The petitioners claimed co-ownership and possession of a parcel of coconut land in Sta. Cruz, Tagoloan, Misamis Oriental, with an area of 1.4892 hectares, based on tax declarations in their father's name and continuous possession. They alleged that the respondents filed a malicious complaint asserting an adverse interest on their property. The respondents, in turn, claimed ownership of the disputed property and asserted that the petitioners were mere squatters. Procedural History The complaint was filed in 1973. The proceedings before the trial court were protracted, spanning over twenty years, with multiple substitutions of parties, amended pleadings, and changes in judges. The trial court, on May 10, 1995, rendered a decision awarding the property to the petitioners. However, on appeal by the respondents, the Court of Appeals set aside the trial court's decision and entered a new one, declaring the petitioners as owners of 1,780 hectares on the eastern portion and the respondents as owners of the remaining 2,000 hectares on the western portion of Lot 21, PLS 799, which has a total area of 3,780 hectares. This decision by the Court of Appeals is now under review. The Petition The petitioners, the heirs of Francisco Nabong, have filed this petition for certiorari under Rule 45 of the Rules of Court assailing the decision of the Court of Appeals. They contend that the appellate court erred in modifying the trial court's decision and dividing the disputed land. The core issue revolves around the conflicting claims regarding the identity, boundaries, and exact measurement of the property in litigation, as evidenced by disparate tax declarations and a commissioner's report that introduced further confusion. The petitioners seek a clarification and resolution of the ownership dispute, arguing that the appellate court's division of the land was not adequately supported by the evidence presented.
Issue(s)
Whether the Court of Appeals erred in modifying the decision of the Regional Trial Court by dividing the disputed property between the petitioners and respondents, given the uncertainty surrounding the property's identity. Whether the identity, boundaries, and exact measurement of the disputed property were sufficiently established to warrant a division by the appellate court.
Ruling
The Supreme Court set aside the decision of the Court of Appeals and remanded the case to the Regional Trial Court of Cagayan de Oro City with instructions to cause a resurvey of the property by a team of surveyors to determine its boundaries based on the parties' respective tax declarations, and thereafter to decide the case accordingly.
Ratio Decidendi
On the issue of the Court of Appeals' modification of the RTC decision and the identity of the property: The Supreme Court found that the fundamental matter requiring clarification was the actual identity of the property in dispute. The conflicting claims, the differing areas cited in the tax declarations (1.4892 hectares for petitioners vs. 2 hectares for respondents), and the commissioner's report, which identified the property as Lot 21, PLS 799 with an area of 3.780 hectares, created a "quandary as to the identity of the property in litigation." The Court noted that the tax declarations did not conform to the boundaries set in Lot 21, making it impossible to identify the subject property with certainty based on the evidence presented. The appellate court's division of the property, while attempting to afford substantial justice, was based on an unclear premise regarding the exact portions claimed and the overall identity of Lot 21. On the issue of the sufficiency of evidence to establish the property's identity and boundaries: The Court highlighted that the trial court's appointment of the municipal assessor as commissioner was less qualified than a geodetic engineer, and the commissioner's report itself did not definitively resolve the discrepancies. Therefore, to equitably decide the case, a more thorough investigation into the property's identity and boundaries was necessary.
Main Doctrine
The Supreme Court remanded the case to the Regional Trial Court for a resurvey of the property by a team of surveyors to definitively ascertain the identity and boundaries of the disputed land, given the conflicting tax declarations and the inadequacy of previous investigations.