GR 136911; (July, 2002) (Digest)
G.R. No. 136911; July 3, 2002
SPOUSES LEON CASIMIRO and PILAR PASCUAL, substituted by their heirs: EMILIO, TEOFILO and GABRIEL, all surnamed CASIMIRO, petitioners, vs. COURT OF APPEALS, NILDA A. PAULIN, MANOLITO A. PAULIN, SUSAN P. MARTIN, SYLVIA P. FARRES, CYNTHIA P. LAZATIN, CELESTINO P. PAULIN and UNIWIDE SALES REALTY AND RESOURCES CORPORATION, respondents.
FACTS
Respondents, the Paulins, were the registered owners of a parcel of land in Las Piñas City. An adjoining property to the north was owned by petitioners, the Casimiros, who were developing the Casimiro Village Subdivision. In 1979, a relocation survey commissioned by the Paulins revealed that the Casimiros’ subdivision had encroached by 3,110 square meters onto the Paulins’ land. The Paulins demanded the cessation of development and the removal of constructions, but the Casimiros denied any encroachment.
The Paulins filed an action for recovery of possession with damages. The trial court initially ruled in favor of the Paulins, ordering the Casimiros to pay the land’s value. However, upon reconsideration, the trial court reversed itself, crediting the survey reports from the Bureau of Lands presented by the Casimiros. On appeal, the Court of Appeals ordered a new relocation survey to be conducted by a team comprising a nominee from each party and a third member from the Land Registration Commission (LRC).
ISSUE
Whether the Court of Appeals erred in relying on the findings of the relocation survey team which concluded that an encroachment existed, and in reinstating the trial court’s original decision in favor of the respondents.
RULING
The Supreme Court denied the petition and affirmed the Court of Appeals’ decision. The core legal principle applied is the conclusiveness of factual findings by the Court of Appeals when supported by substantial evidence. The Supreme Court is not a trier of facts and generally does not re-examine factual determinations made by lower courts.
The petitioners challenged the regularity of the Court of Appeals-ordered relocation survey, alleging that their nominee was excluded from the actual field work and that the resulting plan did not conform to a prior verification plan. The Court found these objections unmeritorious. The appellate court had correctly noted that the petitioners’ surveyor was furnished all field data and was given an opportunity to comment on the final report, which he did not do. The constitution of an LRC team to assist the chairman was deemed a practical measure in the interest of service. The survey team’s final report, which found an encroachment of 3,235 square meters, was thus upheld as credible and procedurally sound.
The petitioners failed to demonstrate that their case fell under any recognized exception to the rule barring factual review, such as a conclusion based on speculation, a grave abuse of discretion, or findings contrary to the evidence on record. The sole factual issue—the location of the common boundary—was resolved by the appellate court based on substantial evidence from a properly conducted survey. Consequently, the Supreme Court found no reason to disturb the factual findings and the reinstated judgment ordering the Casimiros to pay the value of the encroached land and attorney’s fees.