GR 132357; (May, 2006) (Digest)
G.R. No. 132357 ; May 31, 2006
HEIRS OF FLORENTINO REMETIO, represented by PEPITO REMETIO SIOCO, Petitioners, vs. JULIAN VILLARUEL and DIANITO VILLARUEL, Respondents.
FACTS
The Heirs of Florentino Remetio filed a Complaint for Quieting of Title over a parcel of land in Aklan, alleging their late grandfather was the declared owner. They claimed that during a cadastral survey, the land was erroneously surveyed in the name of the respondents’ mother, Basilisa Remetio Villaruel, casting a cloud on their title. The respondents, Julian and Dianito Villaruel, countered that the land they claimed was a distinct lot (Lot No. 4862) surveyed for their mother, separate from the lot referenced by the petitioners.
A court commissioner was appointed to clarify the property’s description. The Commissioner’s Report identified the disputed land as Lot No. 4862, claimed by Basilisa Remetio Villaruel in the cadastral survey. The petitioners subsequently amended their complaint to conform to this description. The trial court ruled in favor of the respondents, declaring them the lawful owners and possessors of Lot No. 4862, a decision affirmed by the Court of Appeals.
ISSUE
Who has the rightful claim of ownership and possession over Lot No. 4862?
RULING
The Supreme Court denied the petition and affirmed the lower courts’ rulings. The legal logic centered on the evaluation of evidence and the principle that factual findings of the trial court, when affirmed by the Court of Appeals, are generally conclusive. The Court found the respondents’ evidence of ownership more credible and substantial. The cadastral survey clearly identified Lot No. 4862 under the name of Basilisa Remetio Villaruel, and the respondents presented corresponding tax declarations consistently referring to that lot, with tax payments made up to 1991.
In contrast, the petitioners’ evidence was insufficient to support their claim. Their presented tax receipts pertained to a different lot (Lot No. 4864), not the disputed Lot No. 4862. The Court upheld the trial court’s finding that the petitioners’ construction of structures on the property was done merely by the tolerance of the respondents, their relatives, and did not constitute proof of adverse ownership. This permissive possession did not negate the respondents’ superior claim derived from the cadastral survey and tax declarations. Therefore, no reversible error was committed by the lower courts in awarding ownership to the respondents.