Angeles v. Pascual
REITERATIONFacts
The Antecedents: Pedro Angeles (Angeles) and Regidor Pascual (Pascual) were registered owners of adjacent lots, Lot 5 and Lot 4, respectively, in Cabanatuan City. Both built houses on their respective lots. A relocation survey of Lot 3, adjacent to Lot 4, revealed that Pascual's house had encroached on Lot 3, leading to Pascual's ejection. Subsequently, Pascual caused a relocation survey of his Lot 4 and discovered that Angeles' house had encroached upon it, occupying 252 square meters of Pascual's 318 square meter lot. Pascual demanded rentals or removal of the encroaching structure, which Angeles refused. Procedural History: Pascual filed a suit against Angeles for recovery of possession and damages. The Regional Trial Court (RTC) ruled in favor of Pascual, finding that Angeles had encroached upon Lot 4 based on the testimony and relocation plan of geodetic engineer Clarito Fajardo, who conducted the survey on-site. The RTC ordered Angeles to remove the encroaching portion of his house. Angeles appealed to the Court of Appeals (CA). The CA affirmed the RTC's finding of encroachment but modified the ruling by applying Article 448 of the Civil Code, giving Pascual the option to either buy the encroaching portion of Angeles' house or sell the portion of Lot 4 occupied by Angeles' house at prevailing market prices. The CA denied Angeles' motion for reconsideration. The Petition: Angeles appealed to the Supreme Court, questioning the CA's reliance on Fajardo's survey over Fernandez's, and arguing that the CA's application of Article 448 was inconsistent with its finding of good faith.
Issue(s)
Whether the Court of Appeals erred in according greater credence to the relocation plan and testimony of geodetic engineer Clarito Fajardo over that of Juan Fernandez, thereby establishing Angeles' encroachment on Pascual's Lot 4. Whether the Court of Appeals erred in applying Article 448 of the Civil Code, which provides options for the landowner when a builder acts in good faith, despite finding that the petitioner (Angeles) was a builder in good faith, and whether such application is consistent with the finding of good faith.
Ruling
The Supreme Court denied the petition for review on certiorari and affirmed the decision of the Court of Appeals. The Court held that the factual findings of the RTC, as affirmed by the CA, regarding the encroachment were conclusive and not subject to review by the Supreme Court, as these involved questions of fact. The Court also found that Angeles was a builder in good faith and that the application of Article 448 of the Civil Code by the CA was proper, giving the landowner, Pascual, the option to buy the encroaching improvement or sell the land to the builder.
Ratio Decidendi
On the issue of credence given to the relocation plan and testimony of geodetic engineer Clarito Fajardo: The Court reiterated that it is not a trier of facts and generally does not re-examine evidence presented in lower courts. The findings of fact by the RTC, especially when affirmed by the CA, are binding on the Supreme Court, unless exceptions apply, none of which were present in this case. The Court emphasized that the dispute was about the actual location of the lots, not the ownership or the metes and bounds as stated in the titles. The testimony of Fajardo, who conducted an on-site survey, was given more weight over Fernandez's "table work," which was based solely on descriptions in the titles. The fact of Angeles' encroachment on Pascual's Lot 4 was thus established by preponderant evidence. On the application of Article 448 of the Civil Code: The Court found that Angeles was indeed a builder in good faith, as he genuinely believed he was building on his own lot and was unaware of any defect in his title or the lot's delineation. This belief is consistent with his insistence that he built his house entirely on his own lot. Article 448 of the Civil Code applies precisely to situations where a person builds in good faith on land owned by another. The provision grants the landowner the right to choose between appropriating the building after paying indemnity or obliging the builder to pay the price of the land. The Court found no inconsistency between the finding of good faith and the application of Article 448, as the latter is predicated on such good faith. The landowner, Pascual, was therefore correctly given the option to exercise his rights under the said article.
Main Doctrine
The Supreme Court affirmed the Court of Appeals' ruling that a builder in good faith, who encroached upon a neighbor's lot, is entitled to the rights provided under Article 448 of the Civil Code, allowing the landowner to either appropriate the building or oblige the builder to pay the price of the land, with the landowner having the option to choose.