VILLANUEVA V. HEIRS OF MENDOZA [ G.R. No. 209132. June 05, 2017 ]

HEIRS OF TERESITA VILLANUEVA

V.

HEIRS OF PETRONILA SYQUIA MENDOZA

G.R. NO. 209132, JUNE 05, 2017

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Summary of Doctrines

• The Supreme Court is not a trier of facts. The function of the Court in petitions for review on certiorari under Rule 45 is limited to reviewing errors of law. The Court defers to and accords finality to the factual findings of the trial courts.
• In an action to recover the ownership of real property, the plaintiff must rely on the strength of his own title and not on the weakness of the defendant's claim.
• To successfully maintain an action for reconveyance, the plaintiff must prove two things: first, the identity of the land claimed and second, his title to the same.
• The burden of proof rests upon the plaintiff to establish their case by a preponderance of evidence. Preponderant evidence is that which is more convincing than the evidence offered in opposition.
• Tax declarations and receipts are not conclusive evidence of ownership. They are merely indicia of a claim of ownership and must be supported by other evidence.

HEIRS OF TERESITA VILLANUEVA

V.

HEIRS OF PETRONILA SYQUIA MENDOZA

G.R. NO. 209132, JUNE 05, 2017

FACTS:

The heirs of Petronila Syquia Mendoza filed a complaint against the heirs of Teresita Villanueva for the declaration of nullity of a free patent and reconveyance of a lot in Tamag, Vigan City. The Syquia heirs claimed co-ownership and long-term possession of the land, asserting that Villanueva had fraudulently obtained a free patent and an Original Certificate of Title (OCT) for a portion of the property. The Regional Trial Court (RTC) dismissed the complaint for lack of preponderant evidence and laches. The Court of Appeals (CA) initially affirmed the RTC, but later reversed its decision on a motion for reconsideration, ruling in favor of the Syquia heirs. The Villanueva heirs then brought the case before the Supreme Court.

ISSUE:

The sole issue before the Supreme Court was whether the Court of Appeals committed a reversible error in its amended decision by allowing the heirs of Syquia to recover the subject property from the heirs of Villanueva.

RULING:

The Supreme Court granted the petition of the Villanueva heirs, reversing and setting aside the amended decision of the Court of Appeals. The Court reinstated the original decision of the CA and the RTC's judgment, which dismissed the complaint of the Syquia heirs.

The Court emphasized that in an action for reconveyance, the plaintiff must rely on the **strength of their own title and not on the weakness of the defendant's claim.** The Syquia heirs failed to discharge their **burden of proof** to establish their case by a **preponderance of evidence**. They could not adequately prove the identity of the land they were claiming due to substantial discrepancies in area and boundaries between their tax declarations and the cadastral survey. The Court reiterated that **tax declarations are not conclusive evidence of ownership** and that the factual findings of the trial court, which had the unique opportunity to observe the witnesses, should be given the highest respect unless there is a clear showing of abuse of discretion, which was not present in this case.