G.R. No. 102297 July 14, 1995
The New Testament Church of God, petitioner, vs. The Honorable Court of Appeals, Sps. Laureano Lucas and Consuelo Gonzales, et al., respondents.

FACTS

Respondent Laureano Lucas was the grantee of two land patents from the Secretary of Agriculture and Natural Resources: a Homestead Patent in 1940 and a Sales Patent in 1950, covering separate parcels in Barrio Dadap, Cauayan, Isabela, with corresponding Original Certificates of Title (OCT Nos. I-7270 and P-1285). In 1956, petitioner New Testament Church of God purchased a parcel of land from the spouses Atienza and Ordonez, which was covered by OCT No. P-1252 derived from a homestead patent. Upon transfer, TCT No. T-7836 was issued in the petitioner’s name.
Private respondents (the Lucas spouses) filed an action for annulment, claiming that portions of the land covered by the petitioner’s title overlapped with the areas covered by their own two titles. The Regional Trial Court ruled in favor of the private respondents, declaring their titles valid and the petitioner’s title null and void insofar as it covered the overlapping portions. The Court of Appeals affirmed this decision, opting to decide based on the evidence on record after recalling an earlier resolution for a relocation survey due to inaction.

ISSUE

Whether the Court of Appeals erred in affirming the trial court’s finding that the petitioner’s land overlapped with the lands of the private respondents.

RULING

The Supreme Court denied the petition and affirmed the Court of Appeals’ decision. The resolution hinged on the application of the rules of evidence and the scope of a petition for review under Rule 45. The core legal issue was factual: whether an overlap existed between the land titles. Private respondents presented three geodetic engineers who testified to the overlapping. Petitioner failed to present any witness to rebut this technical evidence.
The Court emphasized that in civil cases, the burden of proof is established by a preponderance of evidence. The unrebutted testimonies of the geodetic engineers, two of whom were officials of the Bureau of Lands, constituted such preponderant evidence. The petitioner’s argument that these witnesses were naturally biased for being hired by the respondents was insufficient to overcome the disputable presumption that official duties have been regularly performed. Mere suspicion cannot substitute for contrary proof.
Furthermore, the petition was filed as a petition for certiorari under Rule 45, which limits the Supreme Court’s review to errors of law. The Court found no reason to deviate from this rule, as the factual findings of the Court of Appeals were supported by the evidence on record and were not based on a misapprehension of facts. Therefore, the Supreme Court upheld the appellate court’s conclusion that an overlap existed, rendering the petitioner’s title void to that extent.