GR 146082; (July, 2004) (Digest)
G.R. No. 146082 ; July 30, 2004
MELCHOR CUSTODIO, petitioner, vs. ROSENDO F. CORRADO, respondent.
FACTS
Respondent Rosendo Corrado, the registered owner of a residential lot, filed a complaint for recovery of possession and damages against petitioner Melchor Custodio before the Municipal Trial Court (MTC). Corrado alleged that Custodio, without his knowledge and consent, demolished an old house on the lot and constructed a bungalow where he now resides. Custodio claimed he was a legitimate leasehold tenant of Corrado’s father since 1961 and had consent to build the house thirty years prior. During pre-trial, the parties stipulated that the title was in Corrado’s name, Custodio was never Corrado’s tenant, and the construction was without Corrado’s consent.
The MTC dismissed the complaint, finding Custodio’s possession had a legal basis as he was a tenant of Corrado’s father. On appeal, the Regional Trial Court (RTC) reversed the MTC, ordering Custodio to vacate, ruling Corrado was not bound by his father’s alleged permissions. The Court of Appeals affirmed the RTC decision, leading to this petition.
ISSUE
Whether the Court of Appeals erred in affirming the RTC decision ordering Custodio to vacate the property owned by Corrado.
RULING
The Supreme Court denied the petition and affirmed the appellate court’s decision. The legal logic rests on the binding effect of pre-trial stipulations and the limited scope of a Rule 45 review. During pre-trial, the parties clearly stipulated that the lot was registered under Corrado’s name, that Custodio was never a tenant of Corrado, and that the bungalow’s construction was without Corrado’s consent. These judicial admissions are binding and require no further proof; they conclusively establish that Custodio has no right to possess the property as against the registered owner.
The Court emphasized that a petition for review under Rule 45 is limited to questions of law. Factual findings of the Court of Appeals, such as its assessment that the milling tickets presented by Custodio did not conclusively prove a tenancy relationship over the specific disputed lot, are generally final and conclusive. The Supreme Court is not a trier of facts. Since Custodio’s defense hinged on a factual claim of tenancy—which was negated by his own stipulation and the CA’s factual findings—no reversible error of law was committed by the appellate court. Custodio, therefore, had no legal right to occupy the land in defiance of the owner’s will.