G.R. No. 190384; July 5, 2010
HEIRS OF SPOUSES CRISPULO FERRER and ENGRACIA PUHAWAN, represented by ROMEO F. GAZA as Attorney-in-Fact, Petitioners, vs. THE HONORABLE COURT OF APPEALS, NATIONAL POWER CORPORATION, GUIDO ALFREDO DELGADO, FERNANDO ROXAS, ALBERTO PANGCOG, SAMUEL PIEDAD, GREGORIO ALVAREZ, RAFAEL LAGOS, AUGUSTO GO, NAPOLEON EUFEMIO, MELITO SALAZAR, VIRGILIO ODI and MEHOLK SADAIN, Respondents.

FACTS

Petitioners, heirs of spouses Ferrer, sought to enjoin respondent National Power Corporation (Napocor) from selling the Caliraya Hydroelectric Power Plant, claiming ownership over portions of the land (Lot 1873 and Lot 72) on which the plant stood. They demanded payment of damages as rentals for Napocor’s use since 1936. Napocor countered that it acquired portions of Lot 1873 via purchase from the petitioners’ half-sister, Oliva Ferrer, evidenced by two duly notarized and registered deeds of sale from 1940 and 1948. For Lot 72, Napocor asserted a right of way granted by the petitioners’ predecessors, annotated on the title.
The Regional Trial Court dismissed the petitioners’ action. It found their evidence of ownership over Lot 1873 insufficient, relying merely on a Bureau of Lands certification, which is not proof of title. In contrast, it upheld Napocor’s deeds of sale and noted Napocor’s open, continuous possession since 1936. Regarding Lot 72, the RTC ruled the petitioners had no claim as the lot had been adjudicated to other heirs, and the annotated easement in favor of Napocor remained a valid encumbrance. The Court of Appeals affirmed this decision.

ISSUE

Whether the Supreme Court should grant the petitioners’ request for leave to file a second motion for reconsideration of the Court’s earlier Resolutions which denied their petition for certiorari.

RULING

The Supreme Court denied the request. The legal logic is twofold, addressing procedural and substantive grounds. Procedurally, the Court found the petitioners’ original remedy fatally defective. They assailed the CA decision via a Rule 65 petition for certiorari, which is only proper for correcting errors of jurisdiction, not errors of judgment. The petitioners’ grievances—the CA’s alleged failure to appreciate their evidence and arguments—constituted errors of law correctible only by a timely appeal via a petition for review on certiorari under Rule 45. Their resort to Rule 65 was a disingenuous attempt to circumvent the 15-day reglementary period for a Rule 45 appeal, which they had already missed. A second motion for reconsideration is a prohibited pleading and is generally not allowed, as it contravenes the finality of judgments.
Substantively, even if the procedural defects were overlooked, the petition lacked merit. On the claim over Lot 1873, the Court upheld the findings of the lower courts. The deeds of sale presented by Napocor, being notarized and registered, carried the weight of prima facie evidence of their due execution. Against this, the petitioners offered only a Bureau of Lands certification, which does not confer ownership. Their inaction for decades while Napocor possessed and improved the land further weakened their claim. Regarding Lot 72, the annotated easement was a valid encumbrance on the title, and the petitioners failed to prove any superior right to nullify it. Thus, no grave abuse of discretion attended the CA’s affirmance of