G.R. No. 207958 , August 04, 2021
Miguela Quitalig, Petitioner, vs. Eladio Quitalig, Respondent.

FACTS

Petitioner Miguela Quitalig filed a Complaint for Recovery of Possession, Damages and Injunction before the MTCC of Tarlac City. She claimed to be the absolute owner and lawful possessor of a parcel of land acquired from Paz G. Mendoza on March 19, 2001, evidenced by an Acknowledgment of Absolute Sale, and that she and her predecessor-in-interest had been in public, peaceful, and continuous possession for over 30 years. She alleged that in May 2004, respondent Eladio Quitalig, without right and by threats and intimidation, entered the land, erected a fence, plowed and planted it, appropriated the crops, and ousted her. Demands to vacate were ignored. The MTCC ruled in favor of Miguela, ordering Eladio to vacate and pay attorney’s fees. The RTC affirmed the MTCC decision on appeal. The CA reversed the RTC and MTCC decisions, holding that Miguela failed to support her allegations and that Eladio’s evidence was weightier. Miguela filed a Petition for Review before the Supreme Court.

ISSUE

1. Whether the CA erred in not dismissing Eladio’s petition for review despite alleged procedural deficiencies (lack of verification, certificate of non-forum shopping, certified annexes).
2. Whether the CA erred in reversing the decisions of the MTCC and RTC based on an issue not raised by Eladio.
3. Whether the CA erred in its assessment of the probative value of the Tax Declaration and other documents.

RULING

The Supreme Court GRANTED the petition, REVERSED and SET ASIDE the CA Decision and Resolution, and REINSTATED the Decisions of the MTCC and RTC.
1. On procedural deficiencies: The Court found that while Eladio initially failed to comply with the verification and certification against forum shopping requirements under Rule 42 of the Rules of Court, he subsequently submitted a Compliance and Manifestation with the required documents. The Court noted that procedural rules may be relaxed to serve substantial justice, and the subsequent compliance substantially cured the initial defect.
2. On the CA’s review of unraised issues: The Court held that the CA did not err. The CA has the authority to review questions of law and consider issues necessary for a complete resolution of the case, even if not raised by the parties, to prevent a miscarriage of justice.
3. On the probative value of evidence: The Court held that the CA erred in its factual findings. Miguela, as plaintiff, had the burden of proof to establish her ownership and prior possession. She presented an Acknowledgment of Absolute Sale and testimonial evidence of long-term possession, which were sufficient to establish a prima facie case. Eladio’s defense, based on tenancy and ownership by Bonifacio dela Cruz’s heirs, was not substantiated. The tax declaration he presented is not proof of ownership but merely a claim of ownership. The lease receipts he presented did not conclusively prove a tenancy relationship over the specific land in dispute. Miguela’s evidence preponderated over Eladio’s claims. Therefore, as the owner, Miguela has the right to possession of the subject land.