Clemeña v. Bien
REITERATIONFacts
The Antecedents: This case concerns a dispute over ownership and possession of a riceland in Bolo, Municipality of Tiwi, Albay, described in Tax Declaration No. 5299. The underlying conflict originated in the 1940s with consolidated cases filed by Irene Bien (respondents' predecessor) against Pedro Clemeña y Zurbano (petitioners' predecessor) for recovery of possession and ownership. Bien claimed ownership by purchase, asserting that Clemeña y Zurbano unlawfully occupied and usurped the land since 1939, depriving her of harvest shares. Clemeña y Zurbano, in turn, claimed exclusive possession and ownership based on a separate purchase from the same estate. Procedural History: The litigation spanned decades, with both original parties passing away and being substituted by their heirs. The cases were eventually re-raffled to the Regional Trial Court (RTC) of Legaspi City. Initially, on August 10, 1995, the RTC declared petitioners the absolute owners of the land in TD 5299. However, upon reconsideration, the RTC modified its decision on November 13, 1995, ruling that neither party owned the land, which remained part of the estate of the late Pedro Clemeña y Conde. Respondents appealed this order to the Court of Appeals (CA). The CA, in a decision dated April 4, 2002, affirmed the RTC's rulings on other parcels but reversed the decision on TD 5299, declaring respondents the owners and awarding them P118,000 in damages for deprivation of possession and harvest shares. Petitioners' motion for reconsideration was denied on October 1, 2002. The Petition: Petitioners seek review on certiorari under Rule 45 of the Rules of Court, challenging the CA's award of damages. While they no longer dispute respondents' ownership of the property covered by TD 5299, they contend they cannot be held liable for harvest damages because they never possessed the property. They also argue that the CA improperly relied on the testimony of Gregorio Clemeña, one of the respondents' predecessors, deeming it self-serving and an insufficient basis for the damages awarded. The Supreme Court, however, found these arguments without merit, noting that petitioners' predecessor had judicially admitted possession and that a party's testimony in court, subject to cross-examination, is not inherently self-serving.
Issue(s)
Whether petitioners can be held liable for damages for the harvest from the land covered by TD 5299, considering their possession of the land. Whether the testimony of Gregorio Clemeña, a party interested in the outcome, was a proper basis for the award of damages, and the admissibility and weight of such testimony.
Ruling
The petition is devoid of merit. The Court of Appeals' decision and resolution are affirmed.
Ratio Decidendi
On the liability for damages and possession: Petitioners' contention that they never took possession of the land is dismissed. First, their predecessor, Pedro Clemeña y Zurbano, admitted in his answer that the land was in his exclusive possession. This judicial admission conclusively binds petitioners as substituting defendants, as they failed to show it was made through palpable mistake. Second, the issue of possession is a question of fact, which cannot be raised in a petition for review on certiorari, absent any of the recognized exceptions, none of which apply here. The findings of the RTC and CA were not contradictory, and the grounds invoked by petitioners did not warrant a review of factual findings. On the admissibility and weight of Gregorio Clemeña's testimony: Petitioners' argument that Gregorio Clemeña's testimony was self-serving is a misunderstanding of the term. 'Self-serving evidence' refers to acts or declarations made out of court in one's own interest, not to sworn testimony given in court, which is subject to cross-examination. A party's interest may affect credibility but does not automatically render their testimony inadmissible or require it to be disregarded. The Supreme Court has held that interest alone is not a ground for disregarding a party's testimony, and the trier of facts may accept as much of the testimony as it finds credible. Petitioners failed to show that Gregorio Clemeña's testimony was inaccurate or untrue, relying solely on his status as an interested party. Therefore, the appellate court committed no reversible error in relying on his testimony for the award of damages.
Main Doctrine
A party's testimony in court, being sworn and subject to cross-examination, is not considered self-serving evidence and can be a proper basis for an award of damages, even if the witness is interested in the outcome of the case. Interest alone does not ipso facto deprive testimony of probative force.