G.R. No. L-14869, October 27, 1920
THE DIRECTOR OF LANDS, applicant-appellee, vs. THE ROMAN CATHOLIC ARCHBISHOP OF MANILA, objector-appellant. JUSTA DE GUZMAN, ET AL., objectors-appellees.

FACTS:
In 1913, cadastral proceedings were initiated to settle titles to land in Cainta, Rizal. Thirteen lots were claimed by the Municipality of Cainta, the Roman Catholic Archbishop of Manila, and various private individuals. The trial court adjudicated the lots to the private claimants. The Archbishop and the municipality appealed, but the municipality’s appeal was later dismissed. The dispute thus centered between the Archbishop and the private claimants.

During trial, the parties stipulated that the Church held a Spanish-era composition title covering the land. The private claimants presented evidence of open, continuous, and adverse possession for the prescriptive period, as summarized:
– Lots 2176, 2182, 2191: Justa de Guzman possessed since 1895, planting rice and paying taxes.
– Lots 2178, 2180, 2190: Melecio S. Buenaventura possessed since 1882, planting rice.
– Lots 2184, 2185: Justo S. Buenaventura possessed since 1885, cultivating and harvesting.
– Lot 2192: Justo Javier possessed since 1885, planting and harvesting rice.

After the private claimants rested, the Church offered to present additional testimony to rebut the claim of adverse possession and to show that such possession was merely tolerated. The trial court sustained objections that this was not proper rebuttal but part of the Church’s evidence-in-chief and excluded it.

Separately, lots 2186, 2187, 2213, and 2214 were conceded or evidenced to belong to specific private claimants, with the Church not contesting them in its rebuttal offer.

ISSUE:
Whether the trial court erred in refusing to admit the additional evidence offered by the Roman Catholic Archbishop of Manila to rebut the private claimants’ evidence of acquisitive prescription.

RULING:
The Supreme Court partially affirmed and partially reversed the trial court’s judgment.

1. As to lots 2186, 2187, 2213, and 2214: The judgment was affirmed. The Church did not include these lots in its rebuttal offer, and the evidence supported the private claimants’ possession and title.

2. As to the nine remaining lots (2176, 2178, 2180, 2182, 2184, 2185, 2190, 2191, and 2192): The judgment was reversed. The Court held that the trial court erred in excluding the Church’s proffered evidence.

– While cadastral proceedings follow the usual rules of practice and evidence, they are in rem and intended for a comprehensive adjudication of titles. The Court emphasized that technical rules should not be strictly applied at the expense of justice.
– Under the Code of Civil Procedure, a court may, “for good reason, in the furtherance of justice,” permit a party to offer evidence upon their original case even after resting.
– The Church’s offer could be considered proper rebuttal evidence to deny the affirmative fact of adverse possession or to show possession was by tolerance. Even if not strictly rebuttal, the interest of justice and the ascertainment of truth warranted its admission.
– The case was remanded to the trial court to receive the additional evidence from the Church as specified in its offer.

No costs were awarded.