G.R. No. L-44347 September 29, 1988
VICENTE TAN, petitioner, vs. CITY OF DAVAO, respondent.

FACTS

The case involves a parcel of land in Davao City registered in the name of Dominga Garcia. Dominga, her husband, and their three children, including petitioner Vicente Tan, emigrated to China in 1923 and never returned. Dominga died intestate in 1955. In 1962, the City of Davao filed an escheat petition, alleging Dominga and her heirs were presumed dead and that no legal heir existed in the Philippines to inherit the property, warranting its reversion to the state. Ramon Pizarro, a nephew of Dominga’s adoptive mother, opposed the petition. He claimed Dominga’s daughter, Vicenta Tan, was alive, having met her in Davao in 1960 and in Hong Kong in 1966. He presented alleged photographs of Vicenta and documents, including an Extrajudicial Settlement of Estate and a Special Power of Attorney supposedly executed by her in Hong Kong in 1966, to support his claim and his authority to represent her interests.
The trial court rejected Pizarro’s evidence, finding the testimonies of his witnesses identifying Vicenta from childhood memories to be incredible. It granted the escheat petition. The Court of Appeals affirmed, noting Pizarro’s failure to substantiate his claims with official records, such as Vicenta’s departure documents, or to procure her deposition via letters rogatory despite alleging a recent meeting with her in Hong Kong. The appellate court found no reason to overturn the trial court’s factual findings on witness credibility.

ISSUE

Whether the Court of Appeals erred in affirming the trial court’s decision ordering the escheat of the subject property in favor of the state.

RULING

The Supreme Court denied the petition and affirmed the decision. The core legal principle applied is that factual findings of the trial court, especially those based on assessments of witness credibility, are accorded great weight and finality, particularly when affirmed by the Court of Appeals. These findings are binding in a petition for review under Rule 45, which is limited to questions of law. The Court found no reversible error.
The legal logic centered on the requirements for escheat under Rule 92 of the Rules of Court. For escheat to proceed, the petitioner must establish that the property owner has died without a will and that there are no known heirs entitled to the estate. The City of Davao successfully proved that Dominga Garcia, the registered owner, left the Philippines in 1923, died in 1955, and that no heir had appeared in the Philippines to claim the property for decades. The burden then shifted to the oppositor, Pizarro, to prove the existence of a living heir, Vicenta Tan. The trial court and the Court of Appeals uniformly found his evidence—reliant on dubious identification by witnesses and unauthenticated documents—to be insufficient and not credible. His failure to utilize available legal remedies to conclusively prove Vicenta’s existence and claims, such as securing official immigration records or obtaining her deposition, further undermined his opposition. Consequently, the presumption of death of the owner and absence of heirs remained unrebutted, legally justifying the order of escheat.