GR 154026; (June, 2005) (Digest)
G.R. No. 154026 ; June 30, 2005
Spouses Cerilo and Francisca Pasngadan, petitioners, vs. Spouses Victor and Sangsangiyo Ngamilot, respondents.
FACTS
The respondents, spouses Ngamilot, filed a complaint for recovery of possession against the petitioners, spouses Pasngadan, over a parcel of riceland in Mountain Province. The Ngamilots claimed ownership by inheritance, presenting tax declarations and alleging that they had employed a tenant on the land. They asserted that Cerilo Pasngadan unlawfully entered and cultivated a portion of the property in 1978, claiming ownership. Despite a barangay decision in favor of the Ngamilots, Pasngadan persisted. The Regional Trial Court (RTC) dismissed the complaint, ruling the Ngamilots failed to prove ownership and possession.
The petitioners, spouses Pasngadan, countered that the disputed land was given to Francisca by her father. They presented their own series of tax declarations and testimonial evidence to establish their long-term possession and cultivation. The Court of Appeals (CA) reversed the RTC, finding the Ngamilots’ evidence preponderant and ordering the Pasngadans to turn over possession.
ISSUE
Whether the Court of Appeals erred in reversing the trial court and ruling that the respondents have a better right to possession of the disputed property.
RULING
The Supreme Court denied the petition and affirmed the CA decision. The core legal logic rests on the evaluation of evidence in an accion publiciana, where the party with a better right of possession prevails. The Court found that the Ngamilots’ evidence was more credible and directly pertained to the specific disputed property. Their tax declarations, particularly Tax Declaration No. 53 which described boundaries adjoining “Francisca Pasngadan,” coupled with certifications of tax payments, constituted strong evidence of possession in the concept of an owner. Conversely, the Pasngadans’ evidence, including their witnesses’ testimonies and tax documents, was deemed to refer to a different parcel of land adjacent to, not the same as, the property claimed by the Ngamilots. The ocular inspection sketch and the boundary descriptions conclusively showed that the land the Pasngadans were proving was located north of the Ngamilots’ property, not the southern portion under dispute. Therefore, the Ngamilots successfully established a preponderance of evidence supporting their superior claim to possession.