Heirs of Dicman v. Cariño
REITERATIONFacts
The Antecedents: The underlying dispute concerns the ownership and possession of a parcel of land in Baguio City, originally part of the land claim of Mateo Cariño. The subject land, approximately 101,006 square meters, was surveyed in the name of Ting-el Dicman, predecessor-in-interest of the petitioners. However, Sioco Cariño, grandfather of the respondent, had been in possession of the land since 1916 and had advanced expenses for its survey and improvements. A Deed of Conveyance dated October 22, 1928, was executed by Ting-el Dicman, pledging to convey one-half of his title, rights, and interests in the land to Sioco Cariño upon issuance of title, in consideration of expenses incurred. Procedural History: The case traces a complex history through various legal proceedings. Initially, a petition to reopen Civil Reservation Case No. 1 was filed by the heirs of Ting-el Dicman in 1959, claiming ownership over the entire Lot 46. Guzman Cariño, son of Sioco Cariño, opposed this, asserting his ownership over Lot 76-B (half of Lot 46) based on a Deed of Absolute Sale from his father in 1938. A partial judgment in 1963 confirmed title to Lot 76-A for the Dicman heirs but deferred judgment on Lot 76-B. Subsequently, the Supreme Court ruled that the Court of First Instance lacked jurisdiction to reopen such proceedings, leading to the dismissal of the petition in 1978. Guzman Cariño and later his son, Jose Cariño (the respondent), continued possession. In 1983, the heirs of Dicman filed a new complaint for recovery of possession. The Regional Trial Court (RTC) dismissed the complaint, ruling in favor of Jose Cariño, finding he had better right to the land due to acquisitive prescription and laches. The Court of Appeals (CA) affirmed the RTC's decision, and the petitioners then filed a petition for review on certiorari with the Supreme Court. The Petition: The petitioners, heirs of Ting-el Dicman, seek review of the CA's decision affirming the RTC's dismissal of their complaint for recovery of possession. They filed a petition for review on certiorari under Rule 45 of the Rules of Court. The petitioners argue that the CA erred in not considering the invalidity of the Deed of Conveyance due to lack of proper approval under applicable laws for non-Christian tribes, and that the CA erred in applying the ruling in Borromeo v. Franco. They also contend that the CA erred in ruling that the respondent has a better right to the property, despite evidence of their predecessor's application for free patent and continuous possession. The petition also faced challenges regarding the validity of its verification and certification of non-forum shopping, with the respondent arguing that a non-party affiant was used. The Supreme Court ultimately denied the petition, affirming the CA's decision, finding that the respondent had acquired ownership through acquisitive prescription and that the petitioners were guilty of laches, having unduly delayed the assertion of their rights.
Issue(s)
Whether the petition should be dismissed for failure to comply with the requirements for verification and certification of non-forum shopping. Whether the Supreme Court may review the factual findings of the lower courts. Whether the "Deed of Conveyance of Part Rights and Interests in Agricultural Land" is void ab initio for lack of approval, was without valid consideration, or was merely a contract to sell. Whether private respondent acquired ownership through acquisitive prescription. Whether petitioners and their predecessors-in-interest are guilty of laches. Whether Proclamation No. 628 affected the vested rights of the private respondent.
Ruling
The Supreme Court denied the petition and affirmed the decision of the Court of Appeals. The Court held that the petition should be dismissed due to non-compliance with the verification and certification of non-forum shopping requirements, as the affiant was not a principal party. Furthermore, the Court reiterated its policy not to disturb the factual findings of the lower courts, absent any of the recognized exceptions. The Court found that issues regarding the validity of the Deed of Conveyance were raised for the first time on appeal and were thus barred by estoppel. Even if considered, the Court found no basis for nullity. The Court also ruled that private respondent acquired ownership through acquisitive prescription, having possessed the land publicly, continuously, peacefully, in concept of owner, and in good faith with just title for over 50 years. Finally, the Court found that petitioners were guilty of laches, having slept on their rights for an unreasonable and unexplained length of time, causing prejudice to the respondent. Proclamation No. 628 was deemed not to prejudice vested rights already acquired by the respondent.
Ratio Decidendi
On the dismissal for non-compliance with verification and certification of non-forum shopping: The Court emphasized that Section 5, Rule 7 of the Rules of Civil Procedure, requiring the certificate of non-forum shopping to be executed by the plaintiff or principal party, is mandatory. While substantial compliance may be allowed, it requires that the authorized signatory must also be a principal party or co-petitioner when the petitioner is a natural person. In this case, Julio F. Dicman, the affiant, was merely the son of a petitioner and not a principal party himself. Therefore, the petition should be dismissed on this ground alone, as petitioners, being natural persons, cannot appoint a non-party to sign for them, especially when they occupy the best position to know the facts stated in the petition. The Court noted that while the rules were designed to facilitate justice, they should not be interpreted to subvert their objective, but the requirement of the principal party signing is crucial for personal knowledge of the facts stated. On the Supreme Court's power to review factual findings: The Court reiterated its settled rule that it is not a trier of facts and does not re-examine evidence presented by parties, as the findings of the Court of Appeals are conclusive and binding. While exceptions exist, such as grave abuse of discretion or misapprehension of facts, none were shown to apply in this case. Therefore, the Court could not review the factual findings made by the lower courts, which included the continuous, public, peaceful possession in concept of owner by the respondent and his predecessors-in-interest for over 55 years. This principle ensures the finality of judgments and the efficient administration of justice by preventing endless relitigation of factual issues. On the validity of the "Deed of Conveyance of Part Rights and Interests in Agricultural Land" and issues raised for the first time on appeal: The Court held that issues raised for the first time on appeal, such as the alleged nullity of the Deed of Conveyance due to lack of approval, lack of valid consideration, or it being merely a contract to sell, are barred by estoppel. Matters not brought out in the original proceedings cannot be considered on review, as doing so would violate basic principles of fair play, justice, and due process. The Court noted that these arguments were lumped under one issue in the appeal to the CA and were never raised before the RTC. Therefore, the Court could not pass upon these claims as they were belatedly presented. On acquisitive prescription: The Court found that private respondent acquired ownership through acquisitive prescription. The records showed that since 1938, the land had been in the possession of Guzman Cariño, predecessor-in-interest of the private respondent, continuously, publicly, peacefully, in concept of owner, and in good faith with just title, for well beyond the 10-year period required by law. This possession was established through various acts, including tax declarations in Guzman's name, introduction of improvements, and testimony of neighbors. By the time the heirs of Ting-el Dicman sought to establish ownership in 1959, more than 20 years had elapsed since Guzman's possession began in 1938, satisfying the prescription period even before civil interruption. The subsequent dismissal of the case in 1978 left Guzman undisturbed until his death, and his heirs continued possession, solidifying their claim. On laches: The Court ruled that petitioners and their predecessors-in-interest were guilty of laches. Laches is defined as neglect or omission to assert a right, coupled with the lapse of time and circumstances causing prejudice. The four elements of laches were present: (a) conduct giving rise to the situation, (b) delay in asserting rights with knowledge and opportunity to sue, (c) lack of notice that the right would be asserted, and (d) injury or prejudice to the defendant. The Court found no evidence that Ting-el Dicman or his successors questioned the Deed of Conveyance or filed an action to recover possession until long after prescription had set in. Similarly, no action was filed by Sioco Cariño or his Estate to contest the Deed of Absolute Sale. The Court concluded that petitioners had slept on their rights for over 30 years from the Deed of Conveyance or 20 years from the Deed of Absolute Sale, neglecting to take positive steps to assert their claim, thus barring their claim in equity. On Proclamation No. 628: The Court held that Proclamation No. 628, issued in 1960, could not prejudice vested rights already acquired by the private respondent. By the time the proclamation was issued, all rights over the property had already vested in the respondent's predecessors. Executive issuances classifying public land cannot override vested property rights without violating due process. The proclamation's intent to reserve certain lands did not extend to nullifying rights that had already been legally established and possessed.
Main Doctrine
The Court affirmed the Court of Appeals' decision, upholding the respondent's lawful possession and better right to the land in dispute, based on acquisitive prescription and laches, despite petitioners' claims rooted in an earlier deed of conveyance.