G.R. No. L-48787 November 14, 1986
ABADESA MUÑOZ HECHANOVA, MANUEL HECHANOVA, MARIA CLARA HECHANOVA, TERESITA HECHANOVA, ERLINDA HECHANOVA, and POMPEYO HECHANOVA (In substitution of the late Zosimo Hechanova), petitioners, vs. COURT OF APPEALS, ELDIGARDA B. VOCALES and RESTITUTA B. CASTILLO with her husband TIMOTEO CASTILLO, respondents.

FACTS

Private respondents Eldigarda Vocales and Restituta Castillo, heirs of Florencio Barros, filed a complaint for recovery of ownership and possession of a parcel of land against Zosimo Hechanova. They alleged they were the absolute owners and that Hechanova’s possession was based merely on a verbal permission to build a temporary house, which he later refused to vacate. Petitioners, as heirs of Zosimo Hechanova, claimed ownership through a 1930 pacto de retro sale from the respondents to Romualda Gabion, who later sold the lot to Zosimo. They asserted the action was barred by prescription, laches, and estoppel.
The trial court granted petitioners’ motion for a preliminary hearing solely on these affirmative defenses. After the hearing, the court dismissed the complaint, finding the defenses indubitable. On appeal, the Court of Appeals reversed. It found respondents’ allegations more credible, ruled that prescription had not set in, declared respondents the owners, and ordered petitioners to vacate. The appellate court made this determination despite the limited scope of the preliminary hearing.

ISSUE

Whether the Court of Appeals erred in deciding the case on the merits, specifically the issue of ownership, when the trial court’s proceedings were limited to a preliminary hearing on the affirmative defenses of prescription, laches, and estoppel.

RULING

Yes, the Court of Appeals committed reversible error. The Supreme Court reversed its decision and remanded the case for trial on the merits. The legal logic is grounded in procedural due process and the proper scope of appellate review. A preliminary hearing on affirmative defenses under the rules is summary and confined to determining if the defenses are indubitable, warranting dismissal without a full trial. The trial court here received evidence only on prescription, laches, and estoppel.
Consequently, the record was incomplete for a definitive ruling on the central issue of ownership. The Court of Appeals overstepped by making factual findings on ownership based on credibility and evidence not fully presented, such as the alleged absence of a confirming affidavit from Gabion. These were deemed mere conjectures. While appellate courts can sometimes resolve cases on the merits without remand, this is permissible only when the trial court has received all evidence from both parties on the main issues. That condition was absent here. Therefore, to afford both parties a full opportunity to present their evidence, a remand to the trial court for a complete trial on the merits was necessary and ordered.