G.R. No. L-3355

BONIFACIO MENDOZA, ET AL., plaintiffs-appellants, vs. FRANCISCO NABONG, ET AL., defendants-appellees.

January 22, 1908

FACTS:
The plaintiffs, heirs of Simplicia Crespo, filed an action in the Court of First Instance (CFI) of Bulacan to recover certain land. The CFI rendered judgment in favor of the defendants, finding that the plaintiffs failed to show any title or interest in the land, and the defendants, being in possession, could not be dispossessed. The plaintiffs appealed.

The plaintiffs presented documentary evidence, mainly related to an 1888 summary action for money (juicio ejecutivo) against Simplicia Crespo, where land was attached. However, the Court found no document proving a grant of land to Simplicia or the plaintiffs. Lino Reyes, a principal defendant, successfully claimed 14 parcels of the attached land in separate proceedings and in an intervention in the Espejo v. Crespo case, receiving a final judgment in his favor. Although Simplicia Crespo eventually paid her debt, leading to an order to discharge the attachment and return property, there was no evidence this order was ever carried out, or that plaintiffs gained possession.

In a 1896 settlement, Bonifacio Mendoza (for plaintiffs) and Lino Reyes agreed that Lino Reyes owned specific tracts of land in Socol, while acknowledging plaintiffs’ ownership of other property in Socol. This document, however, was deemed proof only against Lino Reyes and not other defendants, and even against Lino Reyes, it essentially confirmed his ownership of a significant portion of the land claimed by plaintiffs.

Plaintiffs later initiated a voluntary jurisdiction proceeding for judicial possession and survey of land in Hagonoy. This proceeding was terminated when other defendants (Juan Flores and Victor Sebastian) formally objected, making the proceeding contentious according to the Law of Civil Procedure, thus conferring no rights upon the plaintiffs.

The plaintiffs also presented parol evidence (witness testimony) regarding their possession. This evidence was found to be vague and unsatisfactory, showing only momentary possession (one or two years, at different times) and failing to sufficiently identify the specific tracts of land allegedly possessed.

ISSUE:
Did the plaintiffs-appellants present sufficient documentary or parol evidence to establish their ownership or a right to possess the land in dispute, thereby overcoming the defendants’ possession?

RULING:
No. The Supreme Court affirmed the judgment of the court below, holding that the plaintiffs-appellants failed to prove their title or interest in the land in question.

1. Documentary Evidence: The documents presented did not show any grant of ownership to Simplicia Crespo or her heirs. The attachment in the summary money action against Simplicia Crespo, initiated at the plaintiffs’ indication, did not constitute proof of ownership. Furthermore, a defendant, Lino Reyes, had already secured final judgments affirming his ownership and right to possession over portions of the disputed land. The subsequent settlement with Lino Reyes, while acknowledging some ownership for plaintiffs, also confirmed Lino Reyes’s title to a significant part of the claimed land and was not binding on the other defendants. The voluntary jurisdiction proceeding initiated by the plaintiffs was legally terminated by the opposition of other parties and thus did not vest any rights in the plaintiffs.

2. Parol Evidence: The testimony regarding the plaintiffs’ and their mother’s possession was “so vague, much of it answers to leading questions, and so unsatisfactory both as to the time and the exact land possessed,” making it “wholly insufficient to prove such a possession as would warrant the maintenance of this action.” The evidence suggested possession was merely momentary and not continuous or clearly identified.

Since the plaintiffs failed to establish any title or interest in the land through either documentary or parol evidence, they could not recover possession from the defendants who were already in possession. The judgment of the CFI was affirmed.