GR L 76386; (October, 1987) (Digest)
G.R. No. L-76386 October 26, 1987
Heirs of Celso Amarante, et al. vs. Court of Appeals, et al.
FACTS
The petitioners, heirs of Malonis Infiel through his wife Elena, filed a complaint for recovery of a twenty-hectare unregistered agricultural land (Lot 1236). They claimed Malonis Infiel occupied and cultivated the land before WWII, and upon his death, it was inherited by his six children from two wives, including Felix Malonis. The respondents, heirs of Felix Malonis, sold Lot 1236 to respondent Gregorio Bolo in 1948, asserting it was owned exclusively by Felix. Petitioners contested this, arguing the 1948 sale covered only a separate five-hectare lot (Lot 1237) owned by Felix, and that Bolo had surreptitiously claimed Lot 1236. The trial court dismissed the complaint, upholding the sale’s validity and declaring Bolo the owner, a decision affirmed by the Court of Appeals.
ISSUE
Whether the Supreme Court should review the factual findings of the lower courts which formed the basis for dismissing the petitioners’ claim.
RULING
The Supreme Court granted the petition and remanded the case for further proceedings. While acknowledging the general rule that factual findings of the trial court and the Court of Appeals are binding, the Court identified exceptions warranting review. It found the lower courts’ decisions were based on a misapprehension of facts. Specifically, the trial court erroneously stated the complaint was filed in 1964, and the Court of Appeals incorrectly noted it was filed in 1963, when the record clearly showed it was refiled in December 1962. This fundamental error in noting a critical procedural fact cast doubt on the thoroughness of the factual review. Furthermore, the Court found the petitioners’ appeal raised substantial factual issues that were not adequately addressed, including the true ownership of Lot 1236, the actual scope of the 1948 sale, and the validity of the conflicting tax declarations. Consequently, the Court set aside the appealed decisions and ordered the Regional Trial Court to reopen the case, receive additional evidence from the petitioners, allow cross-examination and rebuttal, and subsequently submit a detailed report of its findings to the Supreme Court for final resolution on the merits.