Del Fierro v. Seguiran
REITERATIONFacts
The Antecedents: Petitioners filed a complaint for reconveyance of property and cancellation of titles over Lot Nos. 1625 and 1626, agricultural lands situated in Locloc, Palauig, Zambales. The cadastral survey of these lots was conducted in December 1962. Records showed conflicting claimants for these lots. Francisco Santos applied for a free patent over Lot No. 1626 in 1965, which remained pending. The heirs of Miguel del Fierro filed an ejectment case against Lodelfo Marcial and Narciso Marcial in 1964 concerning Lot No. 1197, and won. Lodelfo Marcial mortgaged a parcel of land (Tax Declaration No. 21492, 140,000 sq. m.) to the Rural Bank of San Marcelino, Inc. in 1964, which was foreclosed in 1972, and ownership consolidated in the bank in 1982. On October 28, 1981, Lodelfo Marcial executed a Deed of Absolute Sale over Lot Nos. 1625 and 1626 in favor of respondent Rene Seguiran. On November 9, 1981, respondent purchased the foreclosed property from the bank. Respondent then filed an application for free patent over Lot Nos. 1625 and 1626, which was approved, leading to the issuance of Free Patent Nos. 598462 and 598461 and Original Certificate of Title (OCT) Nos. P-7013 and P-7014 in his name. Procedural History: Petitioners filed a complaint for reconveyance and cancellation of titles on September 13, 1985, alleging that Lodelfo Marcial had no right to convey the lots and that respondent fraudulently applied for free patents. The heirs of Francisco Santos intervened, claiming ownership of Lot No. 1626. Respondent was initially declared in default but was later allowed to file an Answer. The trial court dismissed petitioners' complaint for insufficiency of evidence as to the identity of the properties and the intervenors' complaint for prematurity and insufficiency of evidence. The Court of Appeals affirmed the trial court's decision, holding that petitioners failed to prove the identity of the lands and that the issuance of titles to respondent was not attended by fraud. The Court of Appeals also upheld the dismissal of the intervenors' complaint based on the rule on exhaustion of administrative remedies. The Petition: Petitioners seek review of the Court of Appeals' decision, raising issues regarding the affirmation of the trial court's decision on grounds not raised by the respondent, alleged judicial admission by the respondent, and contradictions between the appellate court's conclusions and the trial court's summary of evidence.
Issue(s)
Whether petitioners are entitled to reconveyance of Lot Nos. 1625 and 1626, and whether the certificates of title of respondent over Lot Nos. 1625 and 1626 should be cancelled. Whether the Court of Appeals erred in affirming the trial court's decision by considering the essential requisite of proving the identity of the property in an action for reconveyance. Whether the Court of Appeals erred in affirming the trial court's decision despite the alleged mistaken judicial admission by the respondent regarding possession in the ejectment case. Whether the Court of Appeals erred in affirming the trial court's decision despite alleged contradictions in the testimonial evidence regarding the identity of the land. Whether the petitioners sufficiently proved both ownership and the identity of the property in their action for reconveyance.
Ruling
The petition is denied. The Court of Appeals' Decision dated October 2, 2001, and its Resolution dated February 11, 2002, in CA-G.R. CV No. 60520, are affirmed.
Ratio Decidendi
On the entitlement to reconveyance and cancellation of titles: The Court affirmed the dismissal of the complaint for reconveyance and cancellation of titles. Article 434 of the Civil Code requires the claimant in an action to recover property to prove two things: first, the identity of the land claimed, and second, their title thereto. Petitioners failed to establish the identity of Lot Nos. 1625 and 1626. The documents they presented pertained to properties located in Barrio Liozon, not Barrio Locloc. Furthermore, the ejectment case cited by petitioners involved Lot No. 1197, and there was no evidence presented to prove that Lot Nos. 1625 and 1626 formed part of Lot No. 1197. The tax declarations designating the lots as 1625 and 1626 were made only in 1985, the same year the lots were titled in the respondent's name, and petitioners could not identify which specific deeds covered these lots. Thus, the identity of the property and the petitioners' title thereto were not sufficiently proven. On the alleged error regarding issues not raised: The Court found no merit in petitioners' argument that the issue of identity was not raised during pre-trial. It reiterated that in an action for reconveyance, proving the identity of the property is an essential requisite that the plaintiff must establish. On the alleged errors regarding judicial admission: The Court clarified that the alleged judicial admission regarding possession in the ejectment case was mistaken. The ejectment case involved Lot No. 1197, not Lot Nos. 1625 and 1626, and the Partial Pre-Trial Order explicitly stated that the respondent did not admit the petitioners' claim of possession over Lot Nos. 1625 and 1626. The survey map also showed Lot Nos. 1197, 1625, and 1626 as distinct lots. Therefore, the respondent did not make a binding judicial admission that would support the petitioners' claim of possession over the disputed lots. On the alleged contradictions in the evidence summary: The Court found the petitioners' contention regarding testimonial evidence to be without merit. The testimonial evidence presented by the petitioners was found to be insufficient to establish the identity of the land. Witnesses admitted they did not know the land area, had no specific tax declarations for Lot Nos. 1625 and 1626, could not identify who resided on Lot No. 1626, and could not link the deeds of transfer to their father to the specific lots in question. They also lacked a survey plan. While one witness mentioned a fishpond and riceland in Lot No. 1625, the specific area was not identified. The Court of Appeals correctly noted that the testimonies failed to indicate precise boundaries or areas and that the failure to clearly identify the lands sought to be recovered was fatal to the action for reconveyance. On the requirement to prove both ownership and the identity of the property: The Court reiterated that the requirement to prove both ownership and the identity of the property was not met.
Main Doctrine
In an action to recover ownership of real property, the claimant must prove both the identity of the land and their title thereto. Failure to establish the identity of the property sought to be recovered is fatal to the claim.