GR 161433; (August, 2006) (Digest)
G.R. No. 161433, August 29, 2006
SUSAN D. DEGOLLACION, Petitioner, vs. REGISTER OF DEEDS OF CAVITE and PILAR DEVELOPMENT CORPORATION, INC., Respondents.
FACTS
Petitioner Susan Degollacion purchased two parcels of land from Antonio Dizon, resulting in the issuance of TCT Nos. T-96011 and T-96019 in her name. She later discovered that a portion of her property, Lot 5766-B, was also covered by TCT No. T-26877 in the name of respondent Pilar Development Corporation. Degollacion filed a Complaint for Cancellation of Title, alleging the corporation’s title was derived from spurious sources. The corporation moved to dismiss, citing procedural defects including the non-attachment of critical annexes to the complaint. The trial court denied the motion but ordered Degollacion to furnish the missing annexes, which she failed to do. After the corporation was declared in default, the court allowed Degollacion to present evidence ex parte.
The trial court dismissed the complaint, finding Degollacion failed to prove her allegations. It noted the photocopy of the corporation’s title she presented was inadmissible without proof of the original’s loss and expressed doubt about the authenticity of her own titles. The Court of Appeals affirmed, giving no weight to the presented evidence, including a letter from the LRA Administrator, as it did not conclusively establish fraud in the issuance of the corporation’s title.
ISSUE
Whether the Court of Appeals erred in affirming the dismissal of the complaint by ignoring or failing to properly appreciate Degollacion’s evidence which allegedly raised sufficient doubt on the validity of the corporation’s title.
RULING
The Supreme Court denied the petition and affirmed the appellate court’s decision. The ruling emphasized that in civil cases, the burden of proof lies with the plaintiff to establish her case by a preponderance of evidence. Degollacion’s evidence, including her own titles, a letter-reply from the LRA, and a photocopy of the corporation’s title, was deemed insufficient to prove that the corporation’s title was fraudulently issued. The LRA letter merely pointed out discrepancies and recommended verification but did not constitute a definitive finding of fraud. The photocopy of the adverse title was inadmissible as secondary evidence because Degollacion did not adequately prove the loss of the original. Furthermore, her failure to submit the annexes to her complaint, which allegedly contained the spurious source titles, despite a court order, was fatal to her cause. The Court held that allegations must be substantiated by competent evidence, and suspicion or doubt cannot substitute for proof. Since Degollacion did not discharge her burden of proof, the dismissal of her complaint was proper.