G.R. No. 220996 . April 26, 2022
ROI GUZMAN DAVID, PETITIONER, VS. CARIDAD D. BUTAY, RESPONDENT.

FACTS

Petitioner Roi Guzman David and defendant Jose Willy entered into a conditional deed of sale on December 4, 2001, over a 3,000-square meter land (subject property). Petitioner took immediate possession. In 2004, upon hearing rumors of another sale by Willy, petitioner erected perimeter fences and a shanty. In 2006, Willy filed a forcible entry case against petitioner, which was dismissed for failure to prosecute, leaving petitioner in peaceful possession until 2009. On November 9, 2009, petitioner learned through his caretaker that Willy, with a group, had entered the property, conducted measurements, and made excavations for construction. Petitioner verified this on November 18, 2009, and filed a forcible entry complaint against Willy on November 19, 2009. During proceedings, petitioner discovered that Willy had sold a 1,553-square meter portion of the subject property to respondent Caridad D. Butay, who had obtained a new tax declaration and whose employees were conducting the construction. Petitioner then amended his complaint to implead respondent. Respondent claimed she bought the land in good faith in July 2009, as there were no occupants or encumbrances on the tax declaration at the time. The Municipal Circuit Trial Court (MCTC) ruled in favor of petitioner, finding prior physical possession and that respondent’s construction was on the portion petitioner possessed. The Regional Trial Court (RTC) affirmed the MCTC decision with modification only as to monetary awards. The Court of Appeals (CA) reversed, dismissing the complaint against respondent, holding that petitioner failed to establish the identity of the land he claimed to possess, as the parties referred to distinct parcels based on their tax declarations.

ISSUE

Whether the Court of Appeals erred in ruling that petitioner failed to prove the identity of the subject land, thereby dismissing the forcible entry complaint against respondent.

RULING

Yes. The Supreme Court reversed the CA Decision and Resolution and reinstated the RTC Decision affirming the MCTC Decision. The Court held that in ejectment cases, the identity of the property is sufficiently established by a description that allows a sheriff or a competent court to identify the land with reasonable certainty. Petitioner’s Amended Complaint, supported by the conditional deed of sale and tax declarations, described the property with particularity—its location, area, boundaries, and tax declaration number. The variance in lot numbers between the tax declarations of petitioner and respondent was not fatal, as both declarations pertained to portions of the same larger parcel originally owned by defendant Willy. The MCTC and RTC, as triers of fact, found based on evidence that respondent’s construction encroached on the portion possessed by petitioner. The CA erred in relying on respondent’s new documentary evidence submitted only on appeal and in overturning the factual findings of the lower courts, which are generally binding. The Court also modified the monetary awards, deleting the awards for moral and exemplary damages and attorney’s fees for lack of basis, but sustained the award of nominal damages and reasonable compensation for the use and occupation of the property.