G.R. No. 176842 ; February 18, 2008
FLORA LEONCIO, FELICIA LEONCIO and CLARITA LEONCIO (In substitution of Elpidio Leoncio, now deceased), petitioners, vs. OLYMPIA DE VERA and CELSO DE VERA, respondents.

FACTS

Petitioners, the granddaughters and daughter-in-law of the late Emilia Lopez, filed a Complaint for Reconveyance of Ownership with Damages against respondents Olympia de Vera (Emilia’s niece) and Celso de Vera. Petitioners claimed that Emilia was the sole owner of a parcel of land in Bustos, Bulacan, having acquired it from the original owner Lorenzo Ramos via a Relinquishment and Waiver of Rights from his heirs, supported by tax declarations from 1933 to 1948 in her name alone. They asserted they were unaware of any disposition of the property by Emilia.
Respondents countered that Emilia was merely a co-owner of the lot with her siblings Macaria and Pascual. Olympia purchased Macaria’s 2/5 share in 1970 and later acquired Pascual’s 1/5 share (which had been sold to the Spouses Raymundo) in 1986. They presented subsequent tax declarations showing the property was declared in the names of Emilia, Macaria, and Pascual (and later the Spouses Raymundo), deeds of sale, and proof of tax payments and occupation by Olympia.

ISSUE

Whether the Court of Appeals committed reversible error in affirming the trial court’s dismissal of the complaint, thereby upholding respondents’ ownership over a 3/5 portion of the subject lot.

RULING

The Supreme Court denied the petition. The core grounds raised by petitioners—challenging the finding that Emilia was not the sole owner, the alleged undue reliance on a presumption of transfer to her siblings, the application of laches, and the failure to award damages—are all questions of fact. A petition for review under Rule 45 is limited to questions of law, which involve doubts concerning what the law is on a given set of facts. In contrast, questions of fact arise when doubts pertain to the truth or falsity of alleged facts and necessitate a review of the evidence’s probative value.
The Court emphasized it is not a trier of facts. Both the Regional Trial Court and the Court of Appeals, after evaluating the evidence, found petitioners’ evidence insufficient. Notably, the crucial “Relinquishment and Waiver of Rights” document was not formally offered in evidence. Conversely, respondents’ evidence, including tax declarations and deeds of sale, was deemed credible. While tax declarations are not conclusive proof of ownership, they are good indicia of possession in the concept of an owner. The factual findings of the lower courts, being supported by evidence, are binding and conclusive absent any showing they fall under established exceptions, which petitioners failed to demonstrate. Thus, no reversible error was committed.