G.R. No. L-74243 November 14, 1986
ASUNCION SANTOS, petitioner, vs. HON. INTERMEDIATE APPELLATE COURT AND GAVINO RAMOS, respondents.

FACTS

Gavino Ramos filed a petition for declaratory relief against Asuncion Santos concerning two deeds of sale he executed in her favor. The first deed, dated August 28, 1961, covered Lot 1317. The second deed, dated September 24, 1964, covered Lot 559-B. Ramos alleged that the second sale of Lot 559-B was merely a substitute for the first sale of Lot 1317 because the original certificate of title for Lot 1317 had been lost, preventing its registration in Santos’s name. He contended the parties never intended the first sale to be effective.
The trial court ruled for Ramos, finding the sale of Lot 559-B substituted the prior sale. This was affirmed by the Intermediate Appellate Court. The appellate court cited substantial evidence: a 1957 agreement showing Ramos had a usufructuary right over Lot 1317; a subsequent written lease of Lot 1317 from Ramos to Santos’s son-in-law, Francisco Castro, including rental payments; a criminal case where Ramos was declared owner of Lot 1317; Santos’s failure to possess or pay taxes on Lot 1317 while possessing Lot 559-B; and the trial court’s credibility findings favoring Ramos’s testimony.

ISSUE

The core issues were: (1) whether a petition for declaratory relief was the proper remedy; (2) whether the trial court erred in quieting title to Lot 1317 in favor of Ramos; and (3) whether it erred in annulling the first deed of sale within a declaratory relief proceeding.

RULING

The Supreme Court dismissed the petition and affirmed the appellate decision. On the procedural issue, the Court held that Santos waived any objection to the propriety of the declaratory relief action. She initially noted a need to question it but later manifested an intent to continue the hearing and file a motion afterward, which she never did. This issue was not raised in her answer or pursued in the trial court; thus, it could not be raised for the first time on appeal. The Court reiterated the doctrine that points of law not brought to the trial court’s attention will not be considered on review.
Regarding the substantive errors, the Court ruled they involved factual questions beyond its scope in a petition for review. The findings of the lower courts—that the second sale was a substitute for the first and that the parties never intended the first sale to be effective—were supported by the evidence on record. The trial court validly inquired into the nature and validity of the title as part of resolving the contract’s interpretation, even within a declaratory relief action. The Supreme Court found no reversible error, as the factual conclusions were firmly grounded in documentary and testimonial evidence, including lease agreements, tax payments, and a prior criminal case judgment.