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EDITHA ALVIOLA v. CA

FACTS:

Victoria Sonjaconda Tinagan purchased two parcels of land on April 1, 1950. One parcel contains an area of 5,704 square meters, while the other contains 10,860 square meters. Victoria and her son Agustin Tinagan took possession of the parcels of land. Petitioners, Editha and her husband, occupied portions of the land and built a copra dryer and store. Victoria died on June 23, 1975, and Agustin died on October 26, 1975. The private respondents, Agustin's wife and children, Demosthenes, Jesus, Zenaida, and Josephine, filed a complaint for recovery of possession against Editha and her husband in March 1988. Petitioners contended that they owned the improvements on the disputed properties and were qualified beneficiaries of the comprehensive agrarian reform program. The trial court ruled in favor of the private respondents, declaring them as the absolute owners of the land and ordering petitioners to vacate and surrender possession. Petitioners appealed to the Court of Appeals, but their appeal was denied. They filed a petition for review on certiorari before the Supreme Court, raising various issues.

ISSUES:

  1. Whether the disputed properties are public lands.

  2. Whether private respondents are the owners of the disputed properties.

  3. Whether petitioners were in bad faith in possessing the disputed properties.

  4. Whether the improvements on the disputed properties are transferable.

RULING:

  1. The Court held that the petition must fail. It ruled that the disputed properties are not public lands based on the overwhelming evidence presented by the private respondents showing their ownership and possession of the said properties. The Court also affirmed the lower court's decision declaring the private respondents as the absolute owners of the disputed properties. Furthermore, the Court held that petitioners were in bad faith in possessing the disputed properties and that the improvements made by the petitioners on the said properties are transferable.

PRINCIPLES:

  • Ownership of public lands cannot be declared by the courts but by the Executive Department of the Government.

  • Ownership and possession of private lands can be proven through evidence.

  • Possession in bad faith can affect the rights of the possessor.

  • Improvements made on private lands are transferable.