GR 30859; (February, 1989) (Digest)
G.R. No. L-30859 February 20, 1989
MARIA MAYUGA VDA. DE CAILLES, and THE HEIRS OF NARCISO, ANGEL, NESTOR and MAURA MAYUGA, petitioners vs. DOMINADOR MAYUGA and NICOLAS Y. OROSA, respondents.
FACTS
The case originated from a petition filed by respondent Dominador Mayuga in 1958, seeking the issuance of a decree of registration for a parcel of land in Las Piñas, Rizal (Lot 9, Plan Psu-11411 Amd-2). He claimed to be the sole heir of Estanislao Mayuga, who was allegedly declared the owner of the land in a 1937 registration proceeding (Land Registration Case No. 1278). The original court records of this proceeding were destroyed by fire during the Japanese Occupation. The petitioners, who are other heirs of Narciso Mayuga (Estanislao’s father), opposed the petition. They denied knowledge of the 1937 proceedings, asserted that Dominador had been disinherited by Estanislao, and claimed co-ownership of the land as Narciso’s heirs. Subsequently, Nicolas Y. Orosa was allowed to intervene, having acquired Dominador’s rights over the property.
ISSUE
The core issue is whether the Court of Appeals erred in affirming the trial court’s finding that the private respondents presented sufficient secondary evidence to prove the existence and content of the destroyed 1937 registration decision, which favored Estanislao Mayuga, and that this evidence was superior to the petitioners’ claims.
RULING
The Supreme Court denied the petition and affirmed the Court of Appeals. The ruling is grounded on the fundamental principle that factual determinations of the Court of Appeals are conclusive and binding on the Supreme Court, absent any recognized exceptions such as a gross misapprehension of facts. The Court found no such exception here. The trial court, whose findings were affirmed by the appellate court, meticulously evaluated the secondary evidence presented. This evidence included certifications from the Land Registration Commission, the approved survey plan bearing a notation referencing the 1937 decision, and the publication of the hearing notice. The Court held this constituted competent secondary evidence of the lost judgment under the Rules of Court. In contrast, the petitioners failed to present any substantive evidence to support their claim of co-ownership. Consequently, the Supreme Court upheld the conclusion that the 1937 decision, which had long become final and executory, established Estanislao Mayuga’s ownership. The rights derived from that decision were correctly adjudged to belong to his successor-in-interest, respondent Orosa. The Court also noted that a final judgment, like the 1937 decision, acquires immutability and incontestability.
