G.R. No. L-2404

FACTS:
Plaintiff-appellee Pedro Sison filed an action in the Court of First Instance of Pangasinan to confirm his title and recover possession of a parcel of rice land in Namalotan, Alcala. He claimed ownership through a deed of sale for one-half of the land and a pacto de retro for the other half, both executed by Vicenta Bugayong in 1902. Sison also presented a possessory information from 1893 in favor of Francisco J. Palisoc (Bugayong’s husband), a court order authorizing Bugayong’s sale, and evidence that Palisoc’s heirs were his sons. Further, he submitted a receipt for palay rent from one defendant and witness testimony attesting to Palisoc’s possession since 1892. The defendants-appellants, Calixto Silva et al., generally denied Sison’s claim and presented oral testimony asserting their own long-term possession, but they introduced no documentary evidence of ownership. The trial court ruled in favor of Sison, declaring him the owner and enjoining the defendants from disturbing his possession.

ISSUE:
Whether the evidence presented by the plaintiff-appellee is sufficient to establish his ownership and right to possession of the disputed land, as against the claims of the defendants-appellants.

RULING:
Yes. The Supreme Court affirmed the trial court’s decision. The plaintiff-appellee’s evidence, consisting of duly registered documents tracing his title back to a 1893 possessory information and corroborated by witness testimony and a rent receipt, sufficiently established his ownership and prior possession. In contrast, the defendants-appellants failed to present any documentary evidence to substantiate their claim of ownership and merely relied on oral testimony, which the trial judge found questionable regarding whether it pertained to the same land described in the complaint. The combination of Sison’s documentary title and evidence of possession through tenants prevailed over the unsubstantiated assertions of the defendants.