Imbat v. Soliven
REITERATIONFacts
The Antecedents: Respondents Spouses Soliven filed a forcible entry case against petitioners Spouses Imbat (and Federico Imbat) for two parcels of riceland in Barangay Anonang, San Fabian, Pangasinan. The Municipal Circuit Trial Court (MCTC) ruled in favor of the Solivens, ordering the Imbats to vacate. The Regional Trial Court (RTC) affirmed the MCTC decision. The MCTC decision became final and executory. After the Imbats re-occupied the premises, they were declared in contempt and eventually vacated after an alias writ of execution. Procedural History: Petitioners Spouses Imbat filed a complaint for quieting of title against respondents, alleging ownership and possession of a parcel of land in Barangay Anonang, San Fabian, Pangasinan, based on a donation from their father. They claimed the land defendants bought was located in Barangay Binday, San Fabian, Pangasinan, and was different from the land subject of the forcible entry case. The RTC ruled in favor of the Solivens, dismissing the complaint and quieting title in their favor. The Court of Appeals affirmed the RTC decision. Petitioners filed a motion for extension to file a motion for reconsideration, which was denied. A subsequent motion for reconsideration was also denied. The Petition: Petitioners fault the Court of Appeals for affirming the RTC decision despite their claim that the property sold to respondents was different from the property subject of the case, and for disregarding a deed of absolute sale executed in favor of petitioner Ricardo Imbat's father in 1949. They also committed procedural errors before the Court of Appeals by filing a prohibited second motion for reconsideration.
Issue(s)
Whether the Court of Appeals erred in affirming the Regional Trial Court’s decision despite the alleged difference in the location of the property sold to the respondents, thereby affecting the validity of the sale. Whether the Court of Appeals erred in disregarding the deed of absolute sale executed in favor of petitioner Ricardo Imbat’s father, and whether this deed pertained to the land in question.
Ruling
The petition is DISMISSED. Costs against petitioners.
Ratio Decidendi
On the issue of property location and the validity of the sale: The Court held that the documentary evidence, specifically the Absolute Sale of Unregistered Land dated December 22, 1975, the Solivens’ Declaration of Real Property, and the Certification from the National Irrigation Administration (NIA), all referred to a property situated in Barrio Anonang, San Fabian, Pangasinan. The Court found that the "Recibo Ti Panangawat Ti Cuarta Nga Ingatang Ti Daga" relied upon by the petitioners was merely a receipt and did not establish with certainty the particulars of the property involved, unlike the Absolute Sale and NIA Certification which were determinative of the land's identity. The Court also noted that the vendors in the Absolute Sale were residents of Binday, a neighboring barangay, which explained a potential discrepancy in location cited in a receipt. On the issue of the deed of absolute sale in favor of Florentino Imbat: The Court found that the Deed of Absolute Sale dated May 28, 1949, was not properly identified and, in any event, appeared to refer to another parcel of land. Furthermore, the Joint Affidavit executed by the supposed witnesses to the sale was considered hearsay as the affiants were not presented in court. The Court also highlighted that the MCTC and RTC decisions in the forcible entry case, which became final and executory, had already established the identities of the parties and the land subject of the case, and that the petitioners had stipulated on these facts during pre-trial.
Main Doctrine
A receipt, without more, does not establish with certainty the particulars of the property involved, unlike a deed of absolute sale or a certification from a government agency which are determinative of the identity of the land.