Leoncio v. De Vera
REITERATIONFacts
The Antecedents: Petitioners, granddaughters and daughter-in-law of the late Emilia Lopez, filed a Complaint for Reconveyance of Ownership with Damages against respondents, Olympia and Celso de Vera. Petitioners alleged that Emilia was the sole owner of a parcel of land (subject lot), having acquired it from the heirs of Lorenzo Ramos. Respondents, however, claimed that Emilia co-owned the lot with her siblings, Macaria and Pascual Lopez, and that Olympia had validly purchased the shares of Macaria and Pascual, thus owning 3/5 of the lot. Respondents presented deeds of sale and tax declarations supporting their claim. Procedural History: The Regional Trial Court (RTC) dismissed the case for lack of merit and ordered petitioners to pay damages, finding that petitioners failed to present a deed of transfer from Lorenzo Ramos to Emilia and that tax declarations in Emilia's name were canceled. The RTC also found respondents' claims valid and their possession to be in good faith. The Court of Appeals (CA) affirmed the RTC's dismissal but deleted the award of damages. The CA noted that the alleged Relinquishment and Waiver of Rights was not offered in evidence. Petitioners' Motion for Reconsideration was denied. The Petition: Petitioners assail the CA Decision and Resolution, raising issues regarding the ownership of the subject lot, the presumption of transfer of ownership, the bar of laches, and the failure to award damages.
Issue(s)
Whether the Court of Appeals committed serious errors of law in holding that the subject lot is not solely owned by the late Emilia Lopez. Whether the Court of Appeals committed serious errors of law by giving undue heavy reliance on the presumption that the late Emilia Lopez could have transferred part of her ownership of the subject lot to her sister Macaria Lopez and brother Pascual Lopez to the extent of 2/5 and 1/5 portions respectively. Whether the Court of Appeals committed serious errors of law in holding that petitioners are already barred by laches in pursuing their ownership over the subject lot against respondents. Whether the Court of Appeals committed serious errors of law in failing to uphold petitioners' ownership of the subject lot and in failing to award them damages. Whether the issues raised involve questions of law or fact.
Ruling
The Petition is DENIED for lack of merit. The assailed Court of Appeals Decision dated August 17, 2006 and Resolution dated February 28, 2007 are AFFIRMED.
Ratio Decidendi
On the ownership of the subject lot: The Court affirmed the findings of the CA and RTC that petitioners failed to overcome the burden of proving their contention that Emilia solely owned the subject lot. While tax declarations and realty tax payments are good indicia of possession in the concept of an owner, they are not conclusive evidence of ownership. The evidence presented by the respondents, including deeds of sale and subsequent tax declarations reflecting co-ownership, sufficiently established their claim over the 3/5 portion of the lot. The absence of a deed of transfer from Lorenzo Ramos to Emilia, as noted by the RTC, further weakened petitioners' claim. On the presumption of transfer of ownership: The Court did not find merit in the petitioners' argument that the CA erred in presuming that Emilia could have transferred part of her ownership. Instead, the CA and RTC relied on the evidence presented by the respondents, which included deeds of sale executed by Macaria and Spouses Raymundo in favor of Olympia, demonstrating a valid transfer of ownership of the co-owned shares. The Court found these deeds to be sufficient proof of the respondents' claim over their respective shares. On the issue of laches: While not explicitly discussed in detail in the ratio, the CA's affirmation of the RTC's dismissal, which implicitly considered the evidence and circumstances, suggests that the claim was deemed barred by laches or that the petitioners failed to establish their right to reconveyance. The fact that petitioners took possession only after Emilia's death, as noted by the RTC, indicates a potential lack of awareness of the true status of the lot and the extent of Emilia's ownership, which could contribute to a finding of laches. On the award of damages: The Court affirmed the CA's modification of the RTC ruling by deleting the award of damages, attorney's fees, and litigation expenses in favor of the respondents. This implies that while the respondents successfully defended their ownership claim, the circumstances did not warrant an award of damages against the petitioners. On the nature of the issues raised: The Court held that the grounds raised by the petitioners, which involve the determination of ownership and the validity of claims based on evidence presented, are essentially questions of fact. A question of law arises when there is doubt as to what the law is on a certain state of facts, while a question of fact arises when the doubt pertains to the truth or falsity of alleged facts. The test is whether the appellate court can resolve the issue without reviewing or evaluating the evidence presented by the litigants. Since the petitioners' grounds require an examination of the probative value of the evidence, they fall outside the scope of a petition for review on certiorari under Rule 45 of the Rules of Civil Procedure. This Court is not a trier of facts and does not weigh evidence anew.
Main Doctrine
Findings of fact of the Court of Appeals, affirming those of the trial court, are generally final and conclusive on the Supreme Court, absent any showing that the case falls under the recognized exceptions. Issues requiring a review of evidence are factual and thus outside the ambit of a petition for review on certiorari under Rule 45.