G.R. No. L-31977, March 22, 1930
CIRILO DADIVAS, ET AL., plaintiffs-appellants, vs. RUFINA BUNAYON, defendant-appellee.

FACTS

The plaintiffs-appellants, Cirilo Dadivas et al., filed an action to recover a parcel of land in Aranguel, Pilar, Capiz, alleging they were the rightful owners. They claimed that in 1919, the defendant-appellee, Rufina Bunayon, entered the land through trickery and deceit and had since unlawfully occupied it, causing them damages. The defendant countered that she was the absolute owner and had been in open, peaceful, adverse, and uninterrupted possession of the land for over thirty years. She also argued that the plaintiffs lacked legal personality to sue and that the complaint failed to state a cause of action. The trial court ruled in favor of the defendant, declaring her the owner of the land and ordering its delivery to her. The plaintiffs appealed, assigning multiple errors, including issues regarding the identity of the land and the validity of their documentary evidence (Exhibit A, an alleged possessory information from 1894).

ISSUE

1. Whether the land subject of the litigation is the same as that described in the defendant’s answer.
2. Whether the plaintiffs’ documentary evidence (Exhibit A) is valid and sufficient to prove ownership.
3. Whether the defendant’s long-term possession establishes her ownership of the land.

RULING

1. Identity of the Land: The Supreme Court affirmed the trial court’s finding that the land in litigation is the one described in the defendant’s answer and held by her. The Court noted that while there were some disparities in the names of adjacent landowners between the complaint and the answer, the natural boundaries were identical. The plaintiffs sued to recover the land held by the defendant, and both parties’ witnesses referred to the same property. Thus, the land in question is that possessed by the defendant.

2. Validity of Plaintiffs’ Evidence: The Supreme Court upheld the trial court’s assessment that Exhibit A was unreliable. The document contained interpolations, erasures, questionable alterations, and inconsistencies in handwriting and ink. It was not recorded in the registry of deeds, and its boundaries did not match those in the complaint. The Court found the trial court’s criticism of the document justified and concluded that it did not substantiate the plaintiffs’ claim of ownership.

3. Defendant’s Ownership Based on Possession: The Supreme Court affirmed that the defendant had been in possession of the land for over forty years at the time the action was filed in 1924, openly, peacefully, and adversely, without any claim from others until the complaint. While payment of land tax alone is not conclusive proof of ownership, it supported the defendant’s claim, as she had paid taxes since 1913, whereas the plaintiffs had not. Additionally, the land was not included in the inventory of the intestate estate of the plaintiffs’ alleged predecessor, Isidora Bermejo. Thus, the defendant’s long-term possession established her ownership.

The Supreme Court affirmed the trial court’s judgment in its entirety, declaring Rufina Bunayon the owner of the land and ordering its delivery to her, with costs against the plaintiffs-appellants.