GR 111952; (October, 1994) (Digest)
G.R. No. 111952 October 26, 1994
JULIO TAPEC and PRISCA GALANO, petitioners, vs. COURT OF APPEALS and LORETO RAGUIRAG, respondents.
FACTS
Petitioners Julio Tapec and Prisca Galano filed a complaint for recovery of ownership over a parcel of land in Paoay, Ilocos Norte, alleging they purchased it through two notarized deeds of sale executed in 1949 and 1950 by Trinidad and Rosario Gonzales, respectively. These deeds were registered under Act No. 3344. They claimed that during a cadastral survey, the land was subdivided, and respondent Loreto Raguirag, without right, threatened to enter Lot No. 7444. Raguirag defended his claim based on a prior, handwritten private document dated 1931, written in Ilocano, wherein the Gonzales brothers sold a pasture land to his grandparents. He asserted ownership through his family’s subsequent possession.
The Regional Trial Court ruled in favor of the petitioners, holding that their notarized and registered deeds of sale, though later in date, prevailed over the unregistered private document. On appeal, the Court of Appeals reversed the decision, applying the rule on ancient documents to the 1931 private writing and giving it more weight, thereby awarding ownership to Raguirag.
ISSUE
Whether the Court of Appeals erred in giving superior weight to the 1931 private document over the petitioners’ notarized and registered deeds of sale from 1949 and 1950.
RULING
Yes. The Supreme Court reversed the Court of Appeals and reinstated the trial court’s decision. The legal logic proceeds as follows: While the 1931 document may qualify as an ancient document under the rules of evidence, which dispenses with proof of its due execution, this does not automatically confer upon it a superior status over a later notarized and registered instrument concerning ownership. Registration under Act No. 3344, though not conferring title like the Torrens system, serves as constructive notice to third parties and is an evidence of good faith. The petitioners’ deeds were notarized and registered, while the respondent’s document remained a private, unregistered writing.
Crucially, the Court found that the respondent failed to prove that the property described in the 1931 document was the same Lot No. 7444 claimed by the petitioners. The descriptions in the competing documents did not clearly refer to identical parcels. Furthermore, the respondent’s own admission that he was merely a tenant-administrator of the lot, and that his aunt was the one who claimed ownership during the cadastral proceedings, severely undermined his claim of ownership by acquisitive prescription. Therefore, the petitioners, who presented registered instruments and demonstrated a history of possession and tax declaration, possessed a superior right to the property. The case fell within an exception allowing review, as the factual findings of the appellate court contradicted those of the trial court.