Racaza v. Abay-Abay
REITERATIONFacts
The Antecedents: Respondents, Spouses Florencio and Eleuteria Abay-abay, filed a complaint in July 1985 for quieting of title, recovery of possession, and damages against several defendants, including Alexander Miel, husband of petitioner Angeles Racaza Miel. The subject property was a residential lot in Poblacion Ubay, Bohol, which the Spouses Abay-abay claimed to have acquired from the estate of Emilia Garces via a Deed of Absolute Sale dated August 12, 1979. They alleged that the defendants began erecting residential houses on the property in mid-1984 without their consent, prompting the lawsuit after demands to vacate were refused. Alexander Miel was declared in default, and the Regional Trial Court (RTC) eventually ordered the demolition of structures on the property, including the Miels' house. Procedural History: Following the RTC's order for demolition, petitioners, as heirs of Pacencia Racaza, filed their own complaint on January 23, 1991, for quieting of title, recovery of possession, and damages against the Spouses Abay-abay. The petitioners claimed co-ownership of the property under Tax Declaration No. 45C1-313 in Pacencia's name, asserting continuous possession disturbed only by the Spouses Abay-abay's lawsuit. They questioned the demolition of their ancestral house, arguing that only Alexander Miel, who had no interest in the property, was impleaded in the original case. The Spouses Abay-abay, in their answer, invoked the prior judgment and writ of execution in Civil Case No. 3920 and raised issues of estoppel and laches. The RTC dismissed the petitioners' complaint, affirming the Spouses Abay-abay's ownership and possession. The Court of Appeals (CA) affirmed the RTC's decision on appeal. The Petition: Petitioners, the Heirs of Pacencia Racaza, filed a Petition for Review on Certiorari under Rule 45 of the Rules of Court, assailing the CA's decision and resolution. They argued that the disputed property is foreshore land owned by the State, that the respondents were buyers in bad faith, and that the demolition order was unconstitutional. Additionally, they sought to admit newly discovered evidence, specifically a CENRO Certification and a cadastral map, to support their claim that the property is foreshore land. The Supreme Court denied the petition, holding that it raised questions of fact beyond the scope of Rule 45 and that the purported newly discovered evidence was not admissible as it could have been presented earlier and did not meet the criteria for newly discovered evidence.
Issue(s)
Whether the Supreme Court can review the factual findings of the lower courts regarding ownership and the nature of the land under a Rule 45 petition. Whether the CENRO Certification and cadastral map constitute 'newly discovered evidence' that can be admitted on appeal. Whether the characterization of the land as 'foreshore land' supports the petitioners' claim for ownership or possession.
Ruling
The petition is denied. The Decision of the Court of Appeals affirming the RTC's ruling is upheld.
Ratio Decidendi
On Issue 1: The Supreme Court held that the petition raised questions of fact which are beyond the coverage of a petition for review on certiorari under Rule 45. Following the rule in Vallacar Transit, Inc. v. Catubig, the Court emphasized that it is not its function to analyze or weigh evidence already considered in the proceedings below, as its jurisdiction is limited to reviewing errors of law. The resolution of factual issues, such as the weight of conflicting evidence regarding possession and ownership, is the primary function of the lower courts. As the petitioners failed to demonstrate that the case falls under any recognized exceptions to the rule, the factual findings of the Regional Trial Court and the Court of Appeals are binding. On Issue 2: The prayer to admit the CENRO Certification and cadastral map as newly discovered evidence was denied because these documents do not meet the legal criteria for such classification. Applying Cabarlo v. People, the Court noted that 'newly discovered evidence' must be discovered after trial and must be of such a nature that it could not have been discovered and produced at the trial with reasonable diligence. The documents offered by the petitioners could have been easily produced and presented during the trial before the court a quo. Furthermore, the Supreme Court is not a trier of facts and is not the proper forum for the substantiation of factual issues that were not ventilated in the lower courts. On Issue 3: Even if the documents were admitted and the land was proven to be foreshore land, this would not benefit the petitioners' claim of ownership. Citing Republic of the Philippines v. CA, the Court explained that foreshore land is part of the public domain and is not subject to private ownership. If the land were indeed foreshore, it would have to be returned to the public domain. Consequently, the petitioners' argument negates their own claim of ownership. Furthermore, only the Republic of the Philippines, as the real party in interest, is authorized to pursue claims against lands of the public domain, as clarified in Manese v. Velasco.
Main Doctrine
A petition for review on certiorari under Rule 45 of the Rules of Court must raise only questions of law, and the Supreme Court is not a trier of facts. Newly discovered evidence cannot be presented for the first time on appeal and must meet specific requisites, including diligence in discovery and materiality. Foreshore land is part of the public domain and not subject to private ownership.