GR L 4061; (December, 1907) (Digest)
G.R. No. L‑4061
December 20, 1907
FACTS
– The heirs of Juan Taguinot filed a complaint to recover a 92‑hectare tract of vacant Crown land in Tanay, asserting that their father had purchased the land in his own name and that the municipality had possessed it for more than a year, thereby depriving the heirs of possession.
– The Municipality of Tanay denied ownership, claiming Taguinot acquired the land only as an agent of the town, on the residents’ expense, and later relinquished title to the municipality.
– Evidence presented: (1) a copy of the sale instrument and title issued to Taguinot; (2) the original 1887 title retained by the gobernadorcillo and a copy given to Taguinot; (3) a private deed signed by Taguinot (May 10 1887) surrendering title to the town; (4) testimonies of numerous witnesses supporting the municipality’s version.
– The trial court dismissed the complaint for lack of proof of actual possession by the Taguinot heirs.
ISSUE
Whether the heirs of Juan Taguinot are entitled to ownership and possession of the land, considering:
1. the validity and effect of the private deed wherein Taguinot purportedly surrendered title to the municipality;
2. the alleged agency relationship between Taguinot and the community of Tanay;
3. the existence of any estoppel preventing the municipality from denying the heirs’ title; and
4. whether the complaint should have been dismissed absent a prior judicial cancellation of Taguinot’s title.
RULING
The Supreme Court affirmed the trial court’s dismissal. It held that:
1. No evidence was adduced showing that Juan Taguinot or his heirs ever possessed the land beyond the title’s issuance; the municipality’s peaceful possession for over a year was unrefuted.
2. The private deed signed by Taguinot, not contested as forged, is admissible as evidence and conclusively shows Taguinot acted as an agent of the town, thereby transferring ownership to the municipality.
3. Under prevailing jurisprudence, a private document, once authenticated and not impeached, binds the signatory and his successors; consequently, the heirs are bound by Taguinot’s relinquishment.
4. No estoppel arose in favor of the heirs because the municipality never repudiated its earlier act of granting title to Taguinot.
5. Dismissal does not require a prior counter‑claim for cancellation of the title; the lack of proven dominion and possession sufficed.
The judgment of the lower court is AFFIRMED; costs are awarded to the municipality.
