GR 109849; (February, 1997) (Digest)
G.R. No. 109849 February 26, 1997
MAXIMINO FUENTES, petitioner, vs. THE HON. COURT OF APPEALS, THIRTEENTH DIVISION, AND VIRGILIO UY, BRIGIDO SAGUINDANG, LEONCIO CALIGANG, ET AL., respondents.
FACTS
Petitioner Maximino Fuentes and private respondents Virgilio Uy, et al., own adjoining parcels of land in Misamis Occidental. Fuentes filed a forcible entry case before the Metropolitan Circuit Trial Court (MCTC), alleging that Uy and others dispossessed him of a 411-square-meter portion of his land. The MCTC ruled against Fuentes, finding that the private respondents did not commit forcible dispossession. The court relied on evidence showing that a predecessor-in-interest of the private respondents, Alfredo Dantes, had bought the area from its original owner, Gadiane, and had improved the dike thereon since 1970. The court noted Fuentes’s inaction for many years despite these improvements, questioning why he only asserted his claim in 1987. The Regional Trial Court (RTC) affirmed the MCTC decision, deleting only a monetary award.
ISSUE
Whether the Court of Appeals erred in affirming the lower courts’ findings that the private respondents did not commit forcible entry and that they had prior physical possession of the disputed property.
RULING
The Supreme Court dismissed the petition. The core issue of who had prior actual possession is a question of fact. Under Rule 45 of the Rules of Court, only questions of law may be raised in a petition for review. The factual findings of the trial court, especially when affirmed by the Court of Appeals, are generally conclusive and binding upon the Supreme Court. The Court enumerated recognized exceptions to this rule, such as when the findings are grounded on speculation or are conclusions without citation of evidence. However, the petitioner failed to demonstrate that any such exception applied in this case. The Court found no arbitrariness in the consistent factual conclusions of the MCTC, RTC, and Court of Appeals, which were supported by the evidence on record, including the testimony of Alfredo Dantes and Fuentes’s prolonged inaction. Consequently, the petition, raising no substantial question of law, was dismissed for lack of merit.