GR 144635; (June, 2006) (Digest)
G.R. No. 144635 ; June 26, 2006
PROGRAMME INCORPORATED, Petitioner, vs. PROVINCE OF BATAAN, Respondent.
FACTS
Petitioner Programme Incorporated leased Piazza Hotel from Bataan Shipyard and Engineering Co., Inc. (BASECO) under a contract expiring on January 1, 1989, after which it continued operations on a month-to-month basis. In April 1989, the Presidential Commission on Good Government (PCGG) sequestered BASECO’s assets, including the hotel’s lot. Subsequently, in July 1989, the Province of Bataan acquired the hotel and land at a public auction for non-payment of taxes, resulting in the cancellation of BASECO’s title and the issuance of a new Transfer Certificate of Title (TCT) in the Province’s name.
Petitioner filed a complaint for injunction and sum of money against BASECO. The Province of Bataan successfully intervened, claiming ownership. The parties agreed to limit the trial to the sole issue of ownership of Piazza Hotel and Mariveles Lodge. The Regional Trial Court ruled in favor of the Province, a decision affirmed by the Court of Appeals, prompting this petition.
ISSUE
Whether the Province of Bataan is the legitimate owner of Piazza Hotel and Mariveles Lodge, entitling it to collect rentals from petitioner.
RULING
The Supreme Court denied the petition and affirmed the lower courts’ rulings. The Court emphasized that factual determinations by the trial court, especially when affirmed by the Court of Appeals, are generally binding and not subject to review in a Rule 45 petition, which is limited to questions of law. No exceptional circumstance warranted a deviation from this rule.
The evidence overwhelmingly established the Province’s ownership. First, it held TCT No. T-128456 for the land. Second, the corresponding Tax Declaration was in the Province’s name, noting transfer via a final bill of sale after the redemption period from the tax auction. Third, petitioner’s own judicial admission in its lease contract with BASECO explicitly recognized BASECO (the Province’s predecessor) as the owner. Such an admission, made in the course of judicial proceedings, is binding unless shown to be a palpable mistake, which petitioner failed to do. Consequently, as the established owner, the Province of Bataan was legally entitled to collect the stipulated rentals from petitioner, the lessee in possession.