GR 1666; (July, 1905) (Digest)
G.R. No. 1666
July 28, 1905
PARTIES:
Plaintiff-Appellant: Paula de Guzman
Defendant-Appellee: Fidel Rivera
FACTS:
Paula de Guzman filed a complaint against Fidel Rivera seeking the annulment of possessory information proceedings instituted by Rivera over a parcel of land, alleging irregularities (non-citation of an adjoining owner and approval by a judge without jurisdiction). She claimed superior right to the land, having purchased it from Jose Torres, and sought damages for her ejectment.
Rivera denied the allegations and filed a cross-complaint, asserting that he (and his wife) were the true purchasers of the land from Jose Torres. He alleged that de Guzman’s possession was merely tolerated and demanded that she vacate the land and remove her house.
The trial court ruled in favor of Rivera, declaring him the owner and ordering de Guzman to remove her house from the premises within a specified period. De Guzman appealed.
ISSUE:
Who between Paula de Guzman and Fidel Rivera has a better right of ownership over the disputed land?
RULING:
The Supreme Court AFFIRMED the trial court’s judgment, ruling in favor of defendant Fidel Rivera.
The Court held that the central question was the identity of the real purchaser from the original owner, Jose Torres. The testimony of Torres himself, corroborated by several witnesses, conclusively established that he sold the land to Fidel Rivera and his wife, not to Paula de Guzman. Torres ratified this sale in a public instrument and delivered the old title deeds to Rivera.
De Guzman failed to present any proof of her alleged purchase of the land. Consequently, she was found to be a mere possessor by tolerance of the true owners (Rivera and his wife) and was occupying the land unlawfully. As a possessor in bad faith, she could not invoke the provisions of the Civil Code (such as Article 361) regarding indemnification for improvements. Her claim for damages and her prayer to be declared owner, without proof of purchase, evidenced her bad faith.
The Court did not pass upon the nullity of the possessory information proceedings, as neither party excepted to that part of the lower court’s judgment.