GR 150173; (September 2007) (Digest)
G.R. No. 150173 ; September 5, 2007
PACIFICO GARING (Deceased), Substituted by his heirs, vs. HEIRS OF MARCOS SILVA, Represented by TERESITA “ESING” VDA. DE SILVA, JOSE ACOSTA, and SPOUSES GENAL and NIDA HAMBALE.
FACTS
Petitioners, the heirs of Pacifico Garing, filed a complaint for reconveyance, claiming ownership over two lots (Lot Nos. 4891-B-1 and 4891-B-2) formed by accretion from the Mangop River adjacent to their property, Lot C. They alleged possession and cultivation of these accretions for years. They contended that these lots were erroneously included within the boundaries of Lot No. 4891-B covered by Original Certificate of Title (OCT) No. P-16110 issued in the name of Marcos Silva. Respondents, the heirs of Silva and an intervenor-purchaser, Jose Acosta, countered that the disputed lots were part of the titled property of Silva. Acosta further argued that the action for reconveyance, filed in 1984, had prescribed since the title was issued in 1969.
ISSUE
Whether the Supreme Court can review the factual findings of the Court of Appeals regarding the ownership of the disputed lots and the claim of accretion.
RULING
The Supreme Court denied the petition, affirming the appellate court’s decision. The Court emphasized that a petition for review under Rule 45 is limited to questions of law. The core issue—whether the lots were formed by accretion and whether petitioners were the rightful owners—was inherently factual. The Court of Appeals had found that petitioners failed to substantiate their claim of accretion with evidence, whereas the respondents’ ownership was evidenced by a valid OCT. The appellate court also correctly applied the principle that a purchaser in good faith, like intervenor Acosta, can rely on the face of the certificate of title. The Supreme Court reiterated that it is not a trier of facts; the factual conclusions of the Court of Appeals, being supported by the record, are final and binding. Thus, absent any showing that these findings fall under established exceptions, such as being unsupported by evidence, the Court declined to re-examine the factual determinations.