**Amancio Sese vs. Hon. Intermediate Appellate Court, Cristeta R. Bagano, and Bertoldo R. Bagano**
### Facts:
The case originates from a dispute over a 3-hectare agricultural land which is part of a larger 23.04-hectare property in Mobo, Masbate. The respondents, Cristeta C. Bagano and Bertoldo R. Bagano, initiated a complaint for recovery of possession and ownership against Amancio Sese, claiming the land through inheritance and purchase. The trial court dismissed the complaint, declaring Sese the rightful owner. Dissatisfied, the Baganos appealed to the Intermediate Appellate Court (now the Court of Appeals), which reversed the trial court’s decision, declaring the Baganos as owners. Sese filed a motion for reconsideration which was denied, leading to the filing of this petition for review under Rule 45 of the Rules of Court, combined with Republic Act No. 5440, to the Supreme Court.
### Issues:
1. Whether the land in question was fully identified by the private respondents.
2. Whether the private respondents have successfully proven their title to the land.
3. Whether the petitioner, Amancio Sese, is the true and absolute owner of the land in question.
4. Whether the Intermediate Appellate Court erred in not affirming the decision of the trial court.
### Court’s Decision:
The Supreme Court found merit in Sese’s contention, focusing on the first issue to resolve the rest. The Court determined that the identity of the land was not adequately proven by the respondents, which undermined their claim of ownership. Key misalignments between the respondents’ claimed boundaries and the actual adjacent land occupiers cast doubt on the identity of the property in dispute. Additionally, inconsistencies in tax declarations and the actual location of the claimed land led the Court to find the claim of ownership by the respondents unsubstantiated. The Supreme Court reinstated the trial court’s decision declaring Amancio Sese as the rightful owner of the land and dismissed the Bagano’s claim due to their failure to prove the land’s identity and their ownership conclusively.
### Doctrine:
The case reaffirms the principle that in actions for recovery of ownership of real property, the claimant must satisfactorily prove not only his ownership but, crucially, the identity of the property in question. Failure to establish the identity of the land renders any claim of ownership baseless.
### Class Notes:
– **Principle of Property Identification:** In property disputes, clearly establishing the identity of the disputed property is prerequisite to a claim of ownership.
– **Proof of Ownership:** Actual occupancy and possession, supported by documentary evidence like tax declarations and deeds of sale, are critical to establishing ownership.
– **Exceptions to the Finality of Appellate Findings:** The Supreme Court may review findings of fact by appellate courts that are unsupported by evidence, contrary to trial court findings, or based on a misapprehension of facts, especially to prevent manifest injustice.
### Historical Background:
This case underscores the challenges in land dispute resolutions in the Philippines, particularly issues related to land identity and ownership proof. It emphasizes the importance of documentary evidence and physical boundaries in establishing property claims, reflecting broader concerns in the Philippine legal system about land title security and clarity.
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