Republic v. Macabagdal
REITERATIONFacts
The Antecedents: The Republic of the Philippines, represented by the DPWH, filed a complaint for expropriation of a parcel of land in Valenzuela City for the C-5 Northern Link Road Project. The owner was initially unidentified, listed as "John Doe YY." The RTC issued a writ of possession after the Republic complied with the deposit requirement. Procedural History: Atty. Conrado E. Panlaque appeared, praying for the substitution of Elena A. Macabagdal as the registered owner. Later, Atty. Ricardo C. Pilares, Jr. filed an Omnibus Motion for Substitution, averring Elena's death and proposing her sole heir, Leonor A. Macabagdal (represented by Eulogia Macabagdal-Pascual), as the substitute. Evidence, including a Deed of Extrajudicial Settlement, was presented to support Leonor's claim. The RTC, in an Order dated July 9, 2010, substituted "John Doe YY" with Elena, and due to her death, substituted her with Leonor as party defendant. The Republic moved for reconsideration, arguing the Deed of Extrajudicial Settlement was unregistered and unpublished, thus invalid under Rule 74. The RTC denied the motion, stating Rule 74 was not a requirement for substitution under Rule 3, Section 16, and that TCT No. T-125922 was registered in Elena's name. The Republic filed a petition for certiorari with the CA, alleging grave abuse of discretion by the RTC in allowing the substitution without sufficient proof of Leonor's lawful right. The Petition: The Republic assailed the CA's Decision and Resolution, which affirmed the RTC's Orders, arguing that the CA erred in finding no grave abuse of discretion by the RTC in allowing Leonor's substitution, primarily due to the alleged insufficiency of the unregistered Deed of Extrajudicial Settlement as proof of heirship.
Issue(s)
Whether the Court of Appeals erred in finding that the Regional Trial Court did not commit grave abuse of discretion amounting to lack or excess of jurisdiction in allowing respondent Leonor A. Macabagdal to substitute Elena A. Macabagdal. Whether the issue presented is a question of fact or law.
Ruling
The petition is unmeritorious. The assailed Decision and Resolution of the Court of Appeals are affirmed.
Ratio Decidendi
On the issue of whether the Court of Appeals erred in finding that the Regional Trial Court did not commit grave abuse of discretion amounting to lack or excess of jurisdiction in allowing respondent Leonor A. Macabagdal to substitute Elena A. Macabagdal: The Court found no grave abuse of discretion on the part of the RTC in allowing the substitution. The Republic's assertion that the Deed of Extrajudicial Settlement was the sole evidence of Leonor's heirship was inaccurate. Leonor also presented two witnesses, Eulogia Macabagdal-Pascual and Nenita Pascual Ramota, along with other pertinent documentary evidence, including Elena's Death Certificate, which established Leonor's identity and interest in the property. Furthermore, the Republic's counsel had indicated that their position on the substitution motion depended on the certification regarding the property's identity with TCT No. T-125922, not on Leonor's status as an heir. Upon confirmation that the property matched the TCT, the Republic's reservation was satisfied, and the propriety of Leonor's substitution was not questioned. Even if the Deed of Extrajudicial Settlement were the only evidence, its unregistered status does not strip it of its evidentiary value regarding Leonor's status and interest. While an unregistered extrajudicial settlement does not bind third persons concerning the adjudication of property, it can still be used to prove heirship. The RTC correctly appreciated the Deed in relation to Leonor's claim as Elena's sole surviving sister. The Court emphasized that the Republic failed to provide any evidence or even allege that Leonor is not the sole surviving heir and sister of Elena, thus failing to meet the burden of disproving the contents of the notarized Deed. On the issue of whether the presented issue is a question of fact or law: The Court determined that the issue presented by the Republic was a question of fact, not a pure question of law. The Republic's petition invited the Court to recalibrate the assessment of evidence by the RTC and CA regarding Leonor's standing as an heir. A question of fact arises when the doubt pertains to the truth or falsehood of facts, requiring the calibration of evidence, credibility of witnesses, and the probability of circumstances. Such questions are not cognizable in a petition for review on certiorari under Rule 45, as the Supreme Court is not a trier of facts and does not re-examine evidence presented in lower courts.
Main Doctrine
The Court reiterated that a question of fact, which requires the calibration of evidence, cannot be raised in a petition for review on certiorari under Rule 45. Furthermore, a notarized Deed of Extrajudicial Settlement, even if unregistered, carries evidentiary weight in establishing heirship, and the burden to disprove its contents rests on the party challenging it.