The Supreme Court has denied a petition questioning ownership of a disputed parcel of land in Banaue, affirming the Court of Appeals resolutions that upheld lower court findings in favor of the respondents.
In a decision in G.R. No. E-03648, the Court ruled that the issues raised—coercion, possession, and ownership—were factual matters that cannot be reviewed in a petition under Rule 45.
The Case
Oscar Umhao (Oscar) claimed that the mother lot was originally owned by his grandmother, Binnulok Pit-ong, and was inherited by his father, Ciano Umhao (Ciano). According to Oscar, sometime in the early 1980's, Ciano allowed his relative, Himmoldang Immatong (Himmoldang), to declare the mother lot in Himmoldang's name for realty tax purposes, so that Himmoldang could plant tiger grass and receive government incentives.
Upon Himmoldang's death, his daughter, respondent Agnes Liwanon (Agnes), had the lot declared in her name. Agnes divided the mother lot into three portions, selling the first to John Wesley Dulawan (Dulawan) and the second to Benjamin and Evangeline Cappleman (the Capplemans), who were the predecessors-in-interest of respondent Jenny C. Buhong (Jenny).
On September 25, 2000, Agnes and Oscar signed an agreement (the 2000 Agreement) for the cancellation of Agnes's tax declarations over the second and third portions, which also provided that Agnes would pay Oscar PHP 100,000. The tax declarations in Agnes's name were cancelled and new ones issued in Oscar's name.
In November 2019, Oscar discovered that Jenny was overseeing excavation activities on the second and third portions, which he said damaged his family's burial ground. He filed a complaint with the National Commission on Indigenous Peoples (NCIP) against Jenny, and later filed the present case against Jenny and Agnes.
The respondents answered that Oscar and his ascendants never owned or possessed the mother lot, which had been the property of Agnes's family for more than 30 years. They averred that the 2000 Agreement was procured by threats of force and violence, including a threat to kill Agnes if she refused to sign.
The Issue
The Court addressed whether the 2000 Agreement was void, whether there was coercion, and whether Agnes and her family held ownership and possession of the disputed property—questions the Court found to be factual matters outside the scope of a Rule 45 review.
The Ruling
The Supreme Court denied the petition. Its disposition reads: "ACCORDINGLY, the present Petition for Review on Certiorari is DENIED. The December 27, 2024 and the November 12, 2025 Resolutions of the Court of Appeals in CA-G.R. SP No. 185298 are AFFIRMED. SO ORDERED."
The Court affirmed that the courts below did not commit reversible error in declaring the 2000 Agreement void for being absolutely simulated. Citing case law, the Court explained that in absolute simulation there is a colorable contract that has no substance, as the parties have no intention to be bound by it, making the contract void.
By the Numbers
- PHP 100,000 — amount Agnes was to pay Oscar under the 2000 Agreement
- PHP 30,000 — amount awarded to Agnes, and another PHP 30,000 to Jenny, as attorney's fees by the MCTC
- September 25, 2000 — date Agnes and Oscar signed the 2000 Agreement
- December 14, 1999 — date of the deed of sale of the second portion to the Capplemans
- More than 30 years — period Agnes and her direct ascendants possessed the mother lot
- December 27, 2024 and November 12, 2025 — dates of the affirmed Court of Appeals Resolutions
- CA-G.R. SP No. 185298 — the Court of Appeals case number
The Court's Reasoning
The Court held that proof of coercion against Agnes is a factual matter that cannot be reviewed in a Rule 45 action, and that Oscar's petition proffered no new arguments, evidence, or factual circumstances that the lower courts may have overlooked. The Court noted eyewitness testimony showing that Agnes's signature on the 2000 Agreement was procured by a death threat made on Oscar's behalf.
The Court emphasized that the finding of simulation rested on five factual circumstances borne out by the record, including that the agreement was premised on an inexistent trust relation, took the form of a barangay-mediated settlement that was never submitted to barangay conciliation, was notarized contrary to the nature of such settlements, and that Oscar never sought the PHP 100,000 payment he was entitled to.
The Court also stated that realty tax declarations are not conclusive evidence of ownership and must be supported by evidence of actual occupation and possession. It noted that the MCTC, the RTC, and the CA were unanimous in giving greater weight to Agnes's evidence of possession by her and her direct ascendants for over 30 years. The Court further observed that Oscar's claim of ownership was inconsistent with his availment of chotag, a familial share in the sale proceeds, for the sale to the Capplemans.
The Court reiterated that a Rule 45 petition must raise pure questions of law and questions of substance of distinctly significant consequence, and found that the present petition failed in this regard.
Source: Supreme Court decision in G.R. No. E-03648, penned by Associate Justice Samuel H. Gaerlan.
This report summarizes a public Supreme Court decision and is not legal advice.