Santos v. Manalili
REITERATIONFacts
The Antecedents: The case involves a 4,608 square-meter parcel of land originally part of the "Furukawa Plantation" in Davao City, which was turned over to the Philippine government and administered by the Board of Liquidators (BOL). Reynaldo Manalili, predecessor-in-interest of respondent Ronald C. Manalili, applied to purchase the land on August 6, 1970, and complied with the down payment requirement. He also declared the land for taxation purposes. On March 25, 1981, nine years after Manalili's application and after the BOL issued a Certification of Full Payment, petitioner Rodolfo Santos protested Manalili's application. An investigation by the BOL's Alien Property Unit concluded that Santos was not the actual occupant and recommended the dismissal of his protest and approval of the sale to Manalili. Manalili complied with other requirements, and the BOL issued a Deed of Absolute Sale on December 16, 1981, which was approved by the Office of the President on December 21, 1981. The Register of Deeds issued TCT 86414 in Manalili's name on January 6, 1982. Procedural History: On April 26, 1982, petitioner Santos filed a complaint for Reconveyance, Damages, Attorney's Fees and/or Annulment of Title. The Regional Trial Court (RTC) initially dismissed the complaint for lack of jurisdiction and non-exhaustion of administrative remedies. Upon appeal, the Intermediate Appellate Court (IAC) reversed the dismissal and remanded the case for trial. The Supreme Court affirmed the IAC's decision. After trial, the RTC rendered a decision on September 20, 1993, dismissing Santos's complaint and ordering him to vacate the land, deliver possession to the private defendants, and pay damages and attorney's fees. Santos appealed to the Court of Appeals (CA), which affirmed the RTC's decision on July 24, 2002. The CA denied Santos's motion for reconsideration on March 3, 2003. The Petition: Petitioner Rodolfo Santos filed the present petition for review on certiorari, faulting the CA for upholding Manalili's better right of possession and for declaring that the sale was not fraudulent and his protest was duly investigated.
Issue(s)
Whether the Court of Appeals erred in upholding that respondent Manalili has the better right of possession over the lot in question. Whether the Court of Appeals erred in declaring that the sale of the lot to the respondent was not fraudulent and that the petitioner's protest was duly investigated.
Ruling
The petition is DENIED and the assailed Decision of the Court of Appeals is AFFIRMED.
Ratio Decidendi
On the issue of better right of possession: The Court affirmed the findings of the two lower courts and the BOL that the Manalilis had a better right of possession. Preponderant evidence established that Reynaldo Manalili filed an Affidavit of Occupancy in 1970, administered the land before moving to Manila, appointed an administrator for the land and its improvements, and paid real estate taxes even before the sale. The Court noted that possession can be exercised through an agent, and the Manalilis' residence in Manila and Pangasinan after the sale was of no moment. In contrast, petitioner's claim of acquiring the land from Ernesto Abalahin, who allegedly bought it from Col. Agsalud, was unsubstantiated. No proof of Col. Agsalud's title or the transfer of rights was presented, and the Deed of Absolute Sale between petitioner and Abalahin did not sufficiently identify the lot, was not notarized, and was unregistered, rendering it not binding on third persons. The Court also found that Abalahin entered the land without permission in 1981, and petitioner, Abalahin, and Lumaad illegally cut trees in 1982, prompting the Manalilis to report their unlawful entry. On the issue of fraud and investigation of protest: The Court found no merit in petitioner's claim of fraud. The law presumes that the BOL acted regularly in recommending the sale and the Office of the President in approving it. Petitioner failed to substantiate his claim of fraud with credible evidence, as mere assertions are insufficient. It was a matter of record that petitioner's protest, filed nine years after Manalili's application and after a Certification of Final Payment was issued, was duly investigated by the BOL. The BOL recommended the sale to Manalili, which was approved by the Office of the President. The Court reiterated the principle that fraud must be established by clear and convincing evidence, a burden petitioner failed to meet. The Court also emphasized that factual findings of an administrative agency, supported by substantial evidence, deserve utmost respect and are generally accorded finality by the courts.
Main Doctrine
The findings of an administrative agency, supported by substantial evidence, are accorded great respect, if not finality, by the courts. Mere assertion of fraud without credible evidence is insufficient to overturn such findings.