Castillo v. CA

G.R. No. 106472 (August 7, 1996)

Facts:

On February 6, 1976, Rosita Masangya filed a complaint for quieting of title with damages against Juan Castillo and Maria Masangya-Castillo in the Regional Trial Court of Aklan (Branch 3). The case arose over a piece of land located in Barrio Candelaria, Municipality of New Washington, Aklan. During the proceedings, the defendants, Juan and Maria Castillo, passed away, and their heirs were substituted as parties.

The trial court established that the land in question, approximately 12,724 square meters, was originally owned by Luis Masangya, who had cultivated it long before World War II. After Luis's death, his children, Isidro and Rosita Masangya, continued to possess the land. Due to non-payment of taxes, the land was sold at public auction in 1937 to Presentacion Relado, who later sold it to Rosita Masangya. The court found that Rosita had established her ownership through various tax declarations and payments, as well as through a confirmation of sale from the heirs of Presentacion Relado.

The trial court ruled in favor of Rosita Masangya, declaring her the lawful owner of the land and ordering the defendants to vacate and restore possession to her. The court also awarded attorney's fees and annual payments for the use of the land.

Legal Issues:

The primary legal issues raised in the petition for review were:

1. Whether the petitioners (the heirs of Juan and Maria Castillo) had superior ownership rights over the land compared to Rosita Masangya.
2. Whether the findings of fact by the lower courts were erroneous or constituted grave abuse of discretion.

Arguments:

The petitioners argued that:

• They had acquired ownership of the land through purchase from Fortunato Quimpo in 1934 and had been in continuous possession since then.
• They contended that Rosita Masangya's claim to ownership only began in 1937, thus invoking the principle of "First in time, first in right."
• They challenged the credibility and sufficiency of the evidence presented by Rosita, labeling it as hearsay and fabricated.

In contrast, Rosita Masangya maintained that:

• She had established her ownership through a clear chain of title, tax declarations, and continuous possession of the land for over ten years.
• The evidence presented by her was credible and supported by official documents, including tax receipts and affidavits from the heirs of Presentacion Relado.

Court's Decision and Legal Reasoning:

The Supreme Court dismissed the petition for lack of merit, reiterating the principle that findings of fact by the trial court, especially when affirmed by the Court of Appeals, are generally conclusive and binding. The Court emphasized that it does not re-evaluate evidence or witness credibility in petitions for review under Rule 45, which are limited to questions of law.

The Court found that the petitioners failed to demonstrate any reversible error or grave abuse of discretion by the lower courts. It noted that the factual findings were well-supported by the evidence on record and that the petitioners' arguments primarily raised factual issues rather than legal questions.

Significant Legal Principles Established:

1. The Supreme Court's jurisdiction in cases from the Court of Appeals is limited to reviewing errors of law; findings of fact are generally conclusive.
2. The principle of "First in time, first in right" applies in property disputes, but ownership must be established through credible evidence and continuous possession.
3. The Court will not re-evaluate evidence or witness credibility unless there are exceptional circumstances warranting such a review.