GR 127833; (January, 1999) (Digest)
G.R. No. 127833 January 22, 1999
TEODORO URQUIAGA and MARIA AGUIRRE, petitioners, vs. THE COURT OF APPEALS, VICENTE CASES and ANITA CRISOSTOMO, respondents.
FACTS
Respondent spouses Vicente Cases and Anita Crisostomo are the registered owners of Lot No. 6532 in Dipolog City, acquired via Sales Patent No. 4511 on May 23, 1969, and covered by Original Certificate of Title No. P-16635. The lot was subdivided in 1979, with Lot No. 6532-B (the subject property) covered by TCT No. T-1425. In 1981 and again in June 1984, workers of petitioners Teodoro Urquiaga and Maria Aguirre entered Lot No. 6532-B to gather nipa palms, claiming ownership. Petitioner Aguirre claimed the lot was donated to her by her parents in 1955, who allegedly possessed it “since time immemorial,” and petitioner Urquiaga claimed possession as administrator. During a barangay conference, petitioner Urquiaga questioned the validity of respondents’ title, alleging actual fraud in its acquisition. Consequently, respondents filed a complaint for quieting of title, recovery of possession, damages, and injunction. The trial court issued a temporary restraining order on August 28, 1985, enjoining petitioners from building a dike or altering the lot’s status, but petitioners repeatedly defied the order through continued construction and cutting of nipa palms. The trial court ruled in favor of respondents, declaring them the absolute owners, upholding their titles, and awarding damages. Both parties appealed. The Court of Appeals modified the decision by deleting the award of actual damages for lack of proof and instead awarded nominal and moral damages, affirming the rest of the judgment.
ISSUE
The primary issue is whether the petitioners have a superior claim of ownership over Lot No. 6532-B based on alleged long-term possession by their predecessors-in-interest, thereby rendering the respondents’ title acquired through fraud and misrepresentation.
RULING
The Supreme Court found no reversible error in the Court of Appeals’ decision and sustained the respondents’ ownership. The Court held that the respondents’ validly documented claim of ownership, supported by OCT No. P-16635 and TCT No. T-1425, must prevail over the petitioners’ verbal claim of ownership based on long possession, which the trial court found inherently weak. The Court of Appeals’ assessment of the evidence was affirmed: the cadastral survey conducted from 1923-1925 already determined the boundaries of the petitioners’ titled property (Lot No. 2623, covered by OCT No. 0-357) and the adjacent Lot No. 4443 (from which the subject lot originated). The petitioners’ predecessors-in-interest never claimed the subject lot during the survey or the subsequent cadastral case. A 1941 cadastral judgment declared the portion that included the subject lot (Lot No. 4443-B) as public land. Furthermore, verification by the Bureau of Lands prior to the respondents’ sales application found the lot free from private claims. The Court also upheld the awards of nominal damages (for the violation of the respondents’ property right), moral damages (for the willful injury to property), and attorney’s fees (as the petitioners’ acts compelled the respondents to litigate).
