G.R. No. 240895 . September 21, 2022.
Republic of the Philippines, represented by the Department of Public Works and Highways, Petitioner, vs. William Rallos, Mateo Rallos, Lucia Rallos, Romeo Rallos, Catherine Rallos, Rochelle Rallos, Christine Rallos, Januario V. Seno, and the Register of Deeds for Cebu City, Respondents.

FACTS

The case involves a 439-square-meter parcel of land in Cebu City, part of V. Rama Avenue, originally registered in 1919 under OCT No. RO-3105 in the names of Victoria, Juan, and Numeriana Rallos. In 1997, the OCT was cancelled and TCT No. 145498 was issued in the names of the private respondents, who claim to be heirs of Numeriana through a will dated 1945. Two consolidated cases were filed before the RTC. In Civil Case No. CEB-21557, respondent Romeo Rallos sought recovery of possession and just compensation from the government, alleging the property was taken for road use without payment. In Civil Case No. CEB-25079, the Republic, through the DPWH, sought reversion and annulment of TCT No. 145498, contending the property had always been part of a national road and that Numeriana died in 1941, making the 1945 will void.
The RTC dismissed both complaints. It found the private respondents failed to prove their filial relationship to Numeriana and Francisco Rallos, and their evidence on heirship was inconsistent and insufficient. Conversely, it ruled the Republic also failed to substantiate its claim that the property was already part of the national road prior to World War II or to present conclusive evidence of Numeriana’s 1941 death. The CA reversed, dismissing the DPWH’s appeal, partly granting Romeo Rallos’s appeal, and remanding the case to the RTC solely for determination of just compensation. The CA held the RTC erred in dismissing the complaint for recovery of possession, finding that the property was registered under Torrens title in the respondents’ names.

ISSUE

Whether the Court of Appeals erred in reversing the RTC’s dismissal of the complaints and in ordering a remand for the determination of just compensation.

RULING

Yes, the Supreme Court reversed the CA and reinstated the RTC’s Joint Judgment. The Court held that the CA committed reversible error. The core legal principle is that a party alleging a fact has the burden of proving it by the required quantum of evidence. In Civil Case No. CEB-21557, the private respondents, as plaintiffs, carried the burden to prove their ownership and right to recover possession or compensation. The RTC correctly found they failed to discharge this burden. Their evidence on heirship was riddled with fatal inconsistencies; Romeo Rallos gave conflicting testimonies on his relationship to Numeriana, and they failed to submit vital documents like birth and death certificates. Without competent proof of their status as rightful heirs, their claim over the property anchored on the will fails.
For Civil Case No. CEB-25079, the Republic, as plaintiff, equally failed to prove its cause of action for reversion. Its claim that the property was always part of a national road and beyond commerce required preponderant evidence, which it did not present. The mere allegation that Numeriana died before executing the will was not sufficiently proven. Consequently, both parties failed to establish their respective claims. The CA therefore erred in granting relief to Romeo Rallos and ordering a remand. A remand for just compensation presupposes a valid and established right to compensation, which was not proven. When both parties fail to substantiate their allegations, the proper remedy is the dismissal of both complaints, as the RTC correctly did. The