G.R. No. 271934 , November 27, 2024
HEIRS OF AQUILINO RAMOS, REPRESENTED BY WILBUR M. RAMOS, MARILOU G. ILAGAN, LYDIA GALARRITA, BENJAMIN GALARRITA, THE MUNICIPAL ASSESSOR OF ALUBIJID, MISAMIS ORIENTAL, AND PROVINCIAL ASSESSOR OF MISAMIS ORIENTAL, PETITIONERS, VS. PROSALITA BAGARES AND DANTON BAGARES, REPRESENTED BY PROSERFINA GALARRITA, RESPONDENTS. [G.R. No. 272834] MARILOU G. ILAGAN, BENJAMIN GALARRITA, AND ELYER GALARRITA, PETITIONERS, VS. PROSALITA GALARRITA BAGARES AND DANTON BAGARES, REPRESENTED BY PROSERFINA GALARRITA, RESPONDENTS.

FACTS

Respondents Prosalita Bagares and Danton Bagares purchased a 3,000-square meter parcel of land from the late Basilia Galarrita-Naguita on July 24, 1995, which was a portion of Lot No. 12020. Subsequently, Aquilino Ramos filed a free patent application over the entire Lot No. 12020 with the Department of Environment and Natural Resources (DENR). Respondents opposed, alleging Aquilino deliberately tampered with the Deed of Sale of Unregistered Land he submitted by changing the lot number from 12019 to 12020. The DENR denied Aquilino’s application. Petitioners Marilou Ilagan, Benjamin Galarrita, Elyer Galarrita, and Lydia Galarrita were buyers of portions of Lot No. 12020 from Aquilino. Respondents filed a complaint for Declaration of Nullity of Tampered Deed of Sale. The Regional Trial Court (RTC) ruled in favor of respondents, declaring the deed void and ordering the cancellation of related tax declarations. The Court of Appeals (CA) affirmed the RTC decision, giving weight to the DENR’s findings and noting Aquilino’s judicial admission during barangay proceedings that he tampered with the deed. Petitioners elevated the case to the Supreme Court via Rule 45, arguing the deed was identifiable despite alterations, that they presented sketch plans, that prescription set in their favor, and that they were buyers in good faith.

ISSUE

Whether the Court of Appeals erred in affirming the RTC Decision which declared the Deed of Sale of Unregistered Land null and void.

RULING

The Supreme Court denied the petitions. The issues raised by petitioners—the nullity of the deed, acquisitive prescription, and good faith—are questions of fact beyond the scope of a Rule 45 petition, which is limited to questions of law. Even if given due course, the petitions fail. The CA correctly affirmed the RTC. The DENR’s finding that Aquilino submitted a tampered document carries the presumption of regularity, which he failed to rebut. Furthermore, Aquilino’s admission during barangay conciliation proceedings that he tampered with the deed constitutes a judicial admission under Section 4, Rule 129 of the Rules of Court, requiring no proof. Consequently, the deed is void and transferred no ownership to Aquilino or his successors. Petitioners’ claim of acquisitive prescription fails as their 26-year possession did not meet the requirements for extraordinary prescription. The award of attorney’s fees was proper as respondents were compelled to litigate to protect their interest.