Facts:
1. On February 10, 1977, Esperanza Borillo, on behalf of herself and her children, filed a complaint before the Court of First Instance (now Regional Trial Court) of Abra against Catalina Borillo and Marcos Borillo.
2. The complaint sought the recovery of several parcels of land located in Bugbuguis, Quillat, Langiden, Abra. These parcels included four parcels declared in the name of Esperanza Borillo (a, b, c, d), and a one-fifth undivided share of two additional parcels (e, f) previously owned by Elpidio Borillo’s father, Venancio Borillo.
3. The lands were unregistered, yet they were declared in 1948 under the name of Elpidio Borillo and he possessed and cultivated them until his death in 1970.
4. Esperanza Borillo claimed that after Elpidio’s death in 1970, her brother-in-law Marcos Borillo and sister-in-law Catalina dispossessed her of the lands in 1971-1972.
5. Catalina Borillo and her brother Marcos responded, asserting that parcels (a), (c), and (d) were sold to her by Elpidio Borillo in 1935, and parcel (b) was sold to Marcos in 1937.
6. They relied on private documents Exhibit “3”, a receipt alleged to indicate sale for P40, and Exhibit “4”, an undated and unsigned deed of sale for the parcels, neither acknowledged before a notary public.
7. The Court of First Instance ruled in favor of Esperanza Borillo on June 3, 1978, relying substantially on the tax declarations and testimonies, declaring them as proper owners.
8. Catalina Borillo appealed the decision to the Court of Appeals (CA-G.R. No. 64536-R), which reversed the regional trial court’s decision on September 3, 1980, favoring Catalina’s claim of ownership due to prescription.
9. The case was brought to the Supreme Court in a petition for review filed by Esperanza Borillo on November 24, 1980.
Issues:
1. Whether the Court of Appeals erred in reversing the trial court’s judgment declaring Esperanza Borillo and her children as owners of the parcels of land.
2. Whether the private documents presented by Catalina Borillo are sufficient to prove the alleged sale of the parcels by Elpidio Borillo.
Court’s Decision:
1. The Supreme Court reversed the decision of the Court of Appeals, affirming the trial court’s ruling favoring Esperanza Borillo.
2. On the first issue, the Court determined that Catalina’s failure to appeal in respect of parcel (b) meant that possession and ownership had long become final in favor of Esperanza’s family.
3. Regarding the second issue, the Supreme Court found that Exhibits “3” and “4” were not admissible as there was no clear proof of execution or witnessing to authenticate them, thereby upholding the trial court’s view that the said lands were not sold.
4. The doctrine of acquisitive prescription was found inapplicable because Elpidio Borillo retained possession until 1970, thus no 30-year prescriptive period.
Doctrine:
1. Documents must be duly executed and authenticated to be admissible as evidence.
2. The parol evidence rule limits testimonial evidence in matters of written agreements, barring supplementing a fundamentally ambiguous document with oral testimony unless a foundation in the writing allows such extension.
3. The principle of tax declarations as prima facie evidence of ownership remains strong when unsupported claims to the contrary are presented.
Class Notes:
1. **Possession and Title**: Tax declarations can serve as prima facie evidence of ownership and continuous possession.
2. **Acquisitive Prescription**: Requires public, peaceful, uninterrupted possession in the concept of owner for 30 years; Elpidio Borillo’s uninterrupted possession negated Catalina’s claim by prescription.
3. **Evidentiary Rules**: Private documents require corroboration through witnessing or evidence of execution to be admissible.
4. **Finality of Judgment**: Timely appeal is imperative; otherwise, judgments become final and unappealable.
Historical Background:
In the early periods of Philippine land ownership, particularly in rural settings, properties were often not registered formally but declared for tax purposes. Possession and family heritage traditions often dominated legal documentation, and during these periods, familial disputes over property became more litigated as agricultural lands gained economic importance. The judiciary system grappled with balancing formal legal requirements for evidence while reflecting longstanding informal local practices.
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