G.R. No. L-24278 September 14, 1973
ELMER ELADJOE, plaintiff-appellee, vs. DAVIS LEAÑO, defendant-appellant.

FACTS

Plaintiff-appellee Elmer Eladjo, the registered owner under Transfer Certificate of Title No. T-1055 of a parcel of land in Benguet, filed a complaint for recovery of possession against defendant-appellant Davis Leaño. Eladjo alleged that Leaño had forcibly seized the land on July 26, 1961. The land was originally covered by Original Certificate of Title No. 54 issued in the name of Justo Leaño, the defendant’s father. The lower court found that Eladjo’s parents, Golonan and Akin, were the true owners but, due to their illiteracy, had entrusted their nephew Justo Leaño to secure the title. Upon issuance, Justo delivered the title to them. After Justo’s death, his widow Magdalena Leaño, as administratrix of his estate, executed a deed of reconveyance in favor of Golonan and Akin with the approval of the probate court. Eladjo inherited the property from his parents.

ISSUE

Whether the Court of Appeals erred in affirming the lower court’s judgment, which was allegedly unsupported by evidence and contrary to law, particularly regarding the existence of a trust, the validity of the reconveyance, and the claim that the disputed land was an accession to the appellant’s property.

RULING

The Supreme Court affirmed the appealed judgment. The appellant’s direct appeal on questions of law was premised on the argument that the judgment was utterly devoid of evidentiary support, constituting a reversible error of law. The Court reiterated that for such a claim to succeed, the appellant must clearly and convincingly demonstrate a complete void of evidence supporting the judgment. The appellant failed to discharge this heavy burden. The factual findings of the lower court, which were not appealed and thus binding, were amply supported by evidence. These findings established an implied trust where Justo Leaño held title in trust for Eladjo’s parents, a trust later honored by his estate through a probate court-approved reconveyance. The appellant’s arguments essentially questioned the weight and credibility of evidence, which are factual matters beyond the scope of a pure question of law. Furthermore, the probate court’s order approving the conveyance was not subject to collateral attack in the instant possession case. No error of law was found in the lower court’s application of legal principles to the established facts, warranting affirmance of the judgment in favor of the registered owner, Eladjo.