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HEIRS OF TEODORO DELA CRUZ v. MADRID

FACTS:

The petitioners filed an action for reconveyance with damages against the private respondents regarding a parcel of land in Isabela. The petitioners claimed to have bought the land from the private respondents in 1959 and have been in possession of it. However, the private respondents obtained a Torrens title for the same land. One of the private respondents denied executing the sale, asserting that the document, if it exists, is fictitious. Another private respondent claimed to be an innocent purchaser for value. The petitioners were unable to present the original deed of sale during the trial and offered a photocopy of the carbon copy as evidence. The trial court ruled the photocopy as inadmissible and dismissed the complaint. The Court of Appeals, while ruling that the photocopy was admissible, held that it had no probative value to prove the sale. The Court of Appeals affirmed the trial court's decision with modification for reimbursement of the improvements. The petitioners argued that they presented other substantial evidence to prove the sale, such as the testimony of the notary public and their long possession of the land.

ISSUES:

  1. Whether Exhibit "A" (photo copy of the purported original carbon copy of the deed of sale) is admissible in evidence despite being secondary evidence.

  2. Whether the petitioners are the rightful owners of the disputed land through the principle of laches or any other ground.

RULING:

  1. Admissibility of Exhibit "A" The Supreme Court concurred with the Court of Appeals that Exhibit "A" was admissible in evidence due to the failure of the private respondents to object when it was offered during the trial. However, the Supreme Court noted that its admissibility does not automatically confer probative value, especially given that Exhibit "A" was merely a photocopy of a carbon copy and lacked the necessary signatures and dates for verification.

  2. Ownership of the Disputed Land The Supreme Court reversed the Court of Appeals' decision and declared the petitioners as the legal owners of the disputed land. The Court emphasized the petitioners’ long and uninterrupted possession of the land since 1959 and the improvements they introduced, which suggested their claim of ownership. The respondents' inaction for almost 30 years, despite being aware of the petitioners' possession, supported the application of the equitable principle of laches against the respondents.

PRINCIPLES:

  • Admissibility vs. Probative Value A piece of evidence may be admissible if not objected to during the trial, but it must still be evaluated for its reliability and probative value.

  • Best Evidence Rule Before secondary evidence can be presented, all originals and duplicates must be accounted for, and no excuse for non-production of the original document can be considered established until all parts are unavailable.

  • Principle of Laches Long inaction or passivity by the rightful owner in asserting their rights over disputed property can preclude them from recovering the same. The rightful owner’s remissness and inaction over time converts their claim into a stale demand.

  • Purchaser in Good Faith A purchaser who is aware of another's possession of a lot cannot later claim to be an innocent purchaser for value. A rightful due diligence investigation must be conducted to verify the status of the property before purchase.