FACTS:

Title: Casimiro Policarpio II v. Spouses Calderon and Renato Macapagal

G.R. No. 146226, November 11, 2004

The petitioners claim that they and their predecessors-in-interest have been in possession of a land since time immemorial. They trace their rights to Casimiro Policarpio, who died in 1945. The land in question was found to have been occupied by the respondents, who allegedly used falsified documents to justify their possession. Petitioners filed a complaint for quieting of title, but the trial court dismissed their complaint. The Court of Appeals affirmed the dismissal of the complaint on the ground that petitioners failed to prove their legal or equitable title to the land.

ISSUES:

1. Whether or not the claim of adverse possession by the respondents is a cloud on the petitioners' interest in the land.

RULING:

1. The Supreme Court denied the petition and affirmed the dismissal of the complaint. The Court held that the alleged cloud on the petitioners' interest in the land has not been proved, as the documents relied upon by respondents were merely marked as exhibits but were never formally offered in evidence by petitioners. The Court also ruled that petitioners failed to establish their legal or equitable title to the land as they did not present any evidence to prove the existence of Casimiro Policarpio and his relationship to them. Thus, the Court found no basis to remove the alleged cloud on petitioners' title to the land.

PRINCIPLES:

• A claim of right based on acquisitive prescription or adverse possession may create a removable cloud on title.

• Documents marked as exhibits during the hearing but not formally offered in evidence cannot be considered as evidence, nor can they be given any evidentiary value.

• In order to prove pedigree, it is necessary to show that the act or declaration was made by a person related to the subject, the relationship is shown by evidence other than the act or declaration, and the act or declaration was made prior to the controversy.