G.R. No. 152141; August 8, 2011
CORNELIO DEL FIERRO, GREGORIO DEL FIERRO, ILDEFONSO DEL FIERRO, ASUNCION DEL FIERRO, CIPRIANO DEL FIERRO, MANUELA DEL FIERRO, and FRANCISCO DEL FIERRO, Petitioners, vs. RENE SEGUIRAN, Respondent.

FACTS

The case involves two parcels of agricultural land, Lot Nos. 1625 and 1626, in Locloc, Palauig, Zambales. The cadastral survey was conducted in December 1962. The claimants for Lot No. 1625 were Lodelfo Marcial versus Miguel del Fierro, and for Lot No. 1626, Lodelfo Marcial versus Francisco Santos and Narciso Marcial. On April 29, 1965, Francisco Santos filed a free patent application for Lot No. 1626, which remained pending. He died on December 9, 1978.
On August 21, 1964, the heirs of Miguel del Fierro (petitioners) filed a forcible entry case against Lodelfo Marcial and Narciso Marcial. The Municipal Trial Court decided in favor of the Del Fierros on October 31, 1972, a decision affirmed by the Court of First Instance on August 1, 1973, ordering the Marcials to vacate.
On June 29, 1964, Lodelfo Marcial mortgaged a parcel of land covered by Tax Declaration No. 21492 (140,000 sq. m.) to the Rural Bank of San Marcelino, Inc. The bank foreclosed the mortgage on December 26, 1972, and consolidated ownership on April 22, 1982.
On October 28, 1981, Lodelfo Marcial executed a Deed of Absolute Sale in favor of respondent Rene Seguiran over Lot Nos. 1625 and 1626, which Marcial had applied for a free patent on in 1967 (covered by Tax Declaration No. 3250 for 1974). On November 9, 1981, Seguiran also purchased Marcial’s foreclosed property from the bank. Seguiran then filed and was granted a free patent application for the lots. On July 11, 1983, Free Patent Nos. 598462 (Lot 1625) and 598461 (Lot 1626) were issued in his name, leading to the issuance of OCT Nos. P-7013 and P-7014 on July 29, 1983.
On September 13, 1985, petitioners filed a Complaint for reconveyance and cancellation of titles against respondent before the RTC of Iba, Zambales. They alleged they were the owners and possessors of the lots, having won the ejectment case against the Marcials. They contended that Marcial had no right to convey the lots, having been adjudged a deforciant, and that Seguiran secured his titles through fraud and bad faith by falsely claiming possession and obtaining a certification that the lots were not in litigation.
Respondent was declared in default, and petitioners presented evidence ex parte. The heirs of Francisco Santos intervened, claiming ownership of Lot No. 1626 as heirs of the registered claimant and applicant.
The RTC dismissed the complaint for insufficiency of evidence regarding the identity of the properties sought to be recovered. The Court of Appeals affirmed this decision.

ISSUE

Whether the Court of Appeals erred in affirming the RTC’s dismissal of the complaint for reconveyance and cancellation of titles due to petitioners’ failure to sufficiently establish the identity of the subject properties (Lot Nos. 1625 and 1626) as the same properties involved in the prior ejectment case and as the properties covered by respondent’s titles.

RULING

The Supreme Court DENIED the petition and AFFIRMED the Court of Appeals’ Decision. The Court held that petitioners failed to prove by preponderance of evidence that the properties subject of their complaint for reconveyance (Lot Nos. 1625 and 1626 under OCTs P-7013 and P-7014) are the same properties involved in the prior ejectment case they won against the Marcials.
The Court emphasized that in an action for reconveyance, the plaintiff must prove not just ownership but, crucially, the identity of the land claimed. Petitioners’ evidence was insufficient to establish this identity. The property description in the ejectment case referred to a “parcel of riceland” in Marala, Palauig, with an area of 140,000 square meters, bounded by a river, the China Sea, and the heirs of Miguel del Fierro, covered by Tax Declaration No. 21492. In contrast, the properties in the reconveyance case are specifically identified as Cadastral Lot Nos. 1625 (72,326 sq. m.) and 1626 (116,598 sq. m.) in Locloc, Palauig, covered by different tax declarations and OCTs. Petitioners did not present any evidence, such as a survey plan or technical description, to demonstrate that the 140,000-square-meter property in the ejectment case is the same as the aggregate area of Lots 1625 and 1626 (totaling 188,924 sq. m.). Testimonies regarding possession were vague and did not conclusively link the two sets of properties. The Court found that petitioners relied on a mistaken assumption of identity without the requisite factual basis. Therefore, the RTC and the CA correctly ruled that petitioners failed to discharge their burden of proof.