Bulay-Og v. Bacalso
REITERATIONFacts
The Antecedents: Enrique Pangilayan executed a Deed of Quitclaim in favor of Matias Bulay-og and Aurelio Balili for one half of Lot No. 4027 (24 hectares). Matias filed a homestead application over the entire lot, which Pangilayan initially contested. They entered into an Amicable Settlement dividing Lot No. 4027 into Portion "A" (for Matias) and Portion "B" (for Pangilayan). Pangilayan then quitclaimed Portion "B" to Salvador Sapallida, who sold it to Francisca Balignot. Balignot sold Lot No. 4027-B to respondent Rebecca Bacalso, who took possession. Meanwhile, Balili, who shared ownership of Lot No. 4027-A with Matias, entered into an Amicable Settlement with Matias, dividing Lot No. 4027-A into northern (for Balili) and southern (for Matias) portions. Sometime in 1985, Matias encroached upon a portion of respondent's lot. Respondent filed a case for recovery of possession with damages against Matias and Purita Bulay-og. Procedural History: The Regional Trial Court (RTC) dismissed respondent's complaint, finding that petitioners' predecessors had been in actual possession since 1957 and had a vested right. The Court of Appeals (CA) reversed the RTC decision, declaring respondent the sole owner of the entire Lot No. 4027. The CA denied petitioners' motion for reconsideration. The Petition: Petitioners seek to annul the CA decision, arguing it erred in awarding the whole Lot No. 4027 to respondent, contending that only a portion (about 12 hectares) was the subject of the case, leaving a remaining portion for petitioners.
Issue(s)
Whether the Court of Appeals erred in awarding the whole of Lot No. 4027, Pls-65 to the respondent. Whether the respondent is entitled to the entire 24 hectares of Lot No. 4027, Pls-65, and whether the petitioners are entitled to a portion of the lot.
Ruling
The Court affirmed the CA decision with modifications, declaring respondent the owner of Lot No. 4027-B (approximately 12 hectares) as denominated in the Amicable Settlement dated March 1, 1967, and declaring petitioners the owners of Lot No. 4027-A (approximately 66,455 square meters) as denominated in the same Amicable Settlement, both portions being part of Lot No. 4027, Pls-65.
Ratio Decidendi
On the issue of awarding the whole of Lot No. 4027, Pls-65 to the respondent: The Supreme Court found merit in the petition, agreeing that the CA erred in awarding the entire Lot No. 4027 to the respondent. The Court noted that the respondent's complaint for recovery of possession specifically declared her ownership and possession of Lot No. 4027-B, consisting of approximately 12 hectares. The evidence showed that Enrique Pangilayan, the original owner of the entire 24-hectare Lot No. 4027, sold only one-half portion to Matias Bulay-og and Aurelio Balili, retaining the other half, which became Lot No. 4027-B. This portion was subsequently sold through several transactions to the respondent. Therefore, the CA's award of the entire Lot No. 4027 was not supported by the evidence and exceeded what was prayed for in the respondent's complaint. The Court reiterated that a party is entitled only to what is prayed for and proven, and the CA's decision was based on a misapprehension of facts and overlooked relevant facts. On the entitlement of the respondent to the entire 24 hectares and the petitioners to a portion of the lot: The Court found the petitioners' prayer for a portion of Lot No. 4027 to be meritorious. Based on the Amicable Settlement between Matias Bulay-og and Aurelio Balili concerning Lot No. 4027-A, this portion was further divided. Records indicated that Balili sold his share, leading to a subdivision plan for Erlinda Amistoso covering the entire Lot No. 4027. This plan delineated specific areas for Erlinda Amistoso, Pedro Amistoso, and Matias Bulay-og. Matias admitted that his portion in the subdivision plan ("Lot No. 4027-A" with 186,455 square meters) included the 12 hectares claimed by the respondent (Lot No. 4027-B under the earlier settlement). Since the respondent's ownership of the 12 hectares was not disputed, the remaining area of approximately 6 hectares (66,455 square meters) from Lot No. 4027-A was awarded to the petitioners. The Court clarified that it could not grant portions to Pedro and Erlinda Amistoso as they were not parties to the original complaint and the RTC had not acquired jurisdiction over them.
Main Doctrine
The Court of Appeals erred in awarding the whole Lot No. 4027, Pls-65 to the respondent when the evidence on record and the respondent's own complaint only supported her claim to a portion thereof (Lot No. 4027-B), while another portion (Lot No. 4027-A) was established to belong to the petitioners' predecessors.