Catapusan v. Court of Appeals

G.R. No. 109262 (November 21, 1996)

SC ruled in favor of heirs from Bonifacio Catapusan's first marriage due to evidence of possession.

Facts:

The case involves a dispute over ownership of a parcel of land located in Wawa, Tanay, Rizal, known as the Wawa lot. The parties are divided into two groups: the petitioners, who are the children from the second marriage of Bonifacio Catapusan (Domingo R. Catapusan, Minelio R. Catapusan, and Filomeno R. Catapusan), and the respondents, who are the heirs from Bonifacio's first marriage (Vicente Catapusan, Jr., Cipriano Catapusan, and others).

Bonifacio Catapusan was first married to Narcissa Tanjuatco, with whom he had four children: Felix, Vicente, Benicio, and Loreto. Narcissa passed away in 1910. In 1927, Bonifacio remarried Paula Reyes, and they had three children, the petitioners. Bonifacio died in 1940. The children from the first marriage, who are the respondents, claimed that the Wawa lot was originally owned by Dominga Piguing and inherited by Narcissa as her paraphernal property. Upon Narcissa's death, the lot passed to her children, who were the predecessors of the respondents.

The petitioners filed an action for partition of the Wawa lot on June 11, 1974, claiming co-ownership with their half-siblings. They argued that the lot belonged to their father, Bonifacio, and should be partitioned among all heirs. To support their claim, they presented tax declarations from adjacent lot owners indicating that the Wawa lot was declared in Bonifacio's name.

In response, the respondents contended that the Wawa lot was inherited from Narcissa and that they had been in open, continuous, and uninterrupted possession of the lot for over 50 years. They also raised defenses of laches and prescription against the petitioners' action. The respondents provided tax declarations showing that the lot was owned by their predecessors and claimed that the petitioners had no documentary proof of ownership.

The trial court dismissed the petitioners' complaint, declaring the respondents as the rightful owners of the Wawa lot and awarding attorney's fees to the respondents. The Court of Appeals affirmed the trial court's decision but set aside the award of attorney's fees.

Legal Issues:

  1. Whether an action for partition includes the question of ownership.
  2. Whether Bonifacio Catapusan had title to the Wawa lot.
  3. Whether the petitioners' action is barred by laches and/or prescription.

Arguments:

  • Petitioners' Arguments:

    • They claimed co-ownership of the Wawa lot, asserting that it belonged to their father, Bonifacio.
    • They presented tax declarations from adjacent lot owners as evidence of Bonifacio's ownership.
    • They argued that the respondents' repudiation of co-ownership only occurred in 1968, thus their action had not lapsed.
  • Respondents' Arguments:

    • They contended that the Wawa lot was inherited from Narcissa and that they had been in continuous possession for over 50 years.
    • They provided tax declarations indicating ownership by their predecessors and argued that the petitioners failed to prove their claim.
    • They invoked laches and prescription, asserting that the petitioners' claim was barred due to the long period of possession by the respondents.

Court's Decision and Legal Reasoning:

The court ruled that an action for partition necessitates a determination of ownership before any division of property can occur. It affirmed that the existence of co-ownership must be established for a partition to be valid. The court found that the petitioners failed to prove Bonifacio's ownership of the Wawa lot, as their evidence (tax declarations of adjacent lot owners and witness testimonies) was insufficient compared to the respondents' tax declarations and evidence of possession.

The court emphasized that the burden of proof lies with the party making the allegation, and the respondents' evidence of ownership through tax declarations and long-term possession outweighed the petitioners' claims. The court also noted that possession by tolerance does not support a claim for title by prescription, and the respondents' possession was characterized as open, continuous, and adverse.

The court concluded that the factual findings of the lower courts were supported by substantial evidence and should not be disturbed. The appeal was denied, and the decision of the Court of Appeals was affirmed in its entirety.

Significant Legal Principles Established:

  1. An action for partition requires a prior determination of ownership.
  2. The burden of proof lies with the party making the claim, and mere allegations without substantial evidence are insufficient.
  3. Possession must be adverse and under a claim of title to support a claim for ownership through prescription.