Demafelis v. Court of Appeals

An appellate court has inherent authority to review unassigned errors when their resolution is necessary to arrive at a just decision, and factual findings of the Court of Appeals on the identity of property in an ejectment case are binding on the Supreme Court absent a showing that such findings are unsupported by the evidence on record.

Petitioner Adelfa Demafelis and respondent Fernando Condez each claimed ownership of parcels of land situated in Barrio San Dionisio, Parañaque City, deriving their titles from different sources. Demafelis purchased a 155-square meter portion from the heirs of Hermogenes Rodriguez on April 17, 1987, covering part of Lot No. Psu-103596 under Tax Declaration No. D-010-07184. Condez, for his part, asserted that he had occupied the property since 1985 and purchased a 75-square meter portion from Antonio F. Bernabe on March 7, 1988, under a document denominated "Kasunduan sa Bilihan ng Lupa." The dispute required determination of whether the two parcels were in fact the same property, a question complicated by the absence of a relocation survey establishing boundaries.

On April 17, 1987, petitioner Adelfa Demafelis purchased from the heirs of Hermogenes Rodriguez a 155-square meter parcel of land forming part of a larger undivided tract identified as Lot No. Psu-103596, covered by Tax Declaration No. D-010-07184, situated in Barrio San Dionisio, Parañaque City. She thereafter allowed respondent Fernando Condez to stay on the property but subsequently asked him to vacate. When respondent refused to leave, petitioner filed a complaint for ejectment against him before the Metropolitan Trial Court (MeTC), Branch 78, Parañaque City.

Respondent Condez maintained a different account of his acquisition and occupancy. He asserted that he had been staying on the property as early as 1985, even before he acquired it, and that on March 7, 1988, he purchased the property from Antonio F. Bernabe under a document titled "Kasunduan sa Bilihan ng Lupa." That document, executed between Bernabe as vendor and Condez as vendee, stated that the land measured approximately 75 square meters and that Condez undertook to pay the total price of ₱18,550.00 in monthly installments of ₱250.00 over a period of twelve years, with a penalty of ₱50.00 per month for any missed installment. The document was signed by both parties on March 7, 1988, at Bernabe Subdivision, Sucat, Parañaque.

The MeTC ordered respondent's eviction, and the RTC affirmed that ruling in its entirety on July 28, 1995, directing the issuance of a writ of execution in favor of petitioner. Respondent then elevated the matter to the Court of Appeals, which undertook a comparison of the two lots claimed by the respective parties. The CA found that the lot sold to respondent Condez, described as Lot 1, Psu-55940 and covered by TCT No. 272, originated from a different parent parcel than the lot claimed by petitioner Demafelis, which was a portion of Lot No. Psu-103592 covered by Tax Declaration No. 010-07184. On the basis of the differing Psu numbers alone, the CA concluded that there was no certainty as to the identity of the property purchased by each party, absent a relocation survey of the boundaries. The CA reversed and set aside the RTC decision and dismissed the ejectment case. Petitioner's motion for reconsideration was denied, prompting the instant petition before the Supreme Court.

• Scope of Appellate Review: Petitioner contended that the Court of Appeals went beyond the issues raised in the Petition for Review, as the matter of identity of the property subject of ejectment was never raised before the MeTC and first surfaced only in the CA decision under review.
• Identity of Property: Petitioner argued that the Court of Appeals overlooked the Location Plan submitted in evidence before the lower court, which she claimed established the identity of the property subject of ejectment.
• Nature of the Kasunduan: Petitioner maintained that the Court of Appeals erred in implying that the Kasunduan sa Bilihan ng Lupa transferred ownership to respondent, contrary to the lower courts' findings that the document was merely an agreement to enter into a contract to sell and did not transfer ownership.
• Remand Instead of Dismissal: Petitioner argued that the Court of Appeals should have remanded the case to the court of origin for the purpose of establishing the identity of the property rather than dismissing the ejectment case outright.

• Appellate Authority: Respondent countered that the Court of Appeals is clothed with ample authority to review matters not assigned as errors if their consideration is necessary in arriving at a just decision.
• Factual Finding on Identity: Respondent argued that the issue of identity of the subject land is a question of fact already determined by the appellate court, which cannot be raised in a Petition for Review on Certiorari and cannot be disturbed unless the findings are unsupported by the evidence.
• Sufficiency of CA Findings: Respondent reiterated that the CA's findings as to the lack of identity of the subject lot are amply supported by evidence, are conclusive on the parties, and are not reviewable by the Supreme Court.

• Scope of Appellate Review: Whether the Court of Appeals went beyond the issues raised in the Petition for Review in resolving the question of property identity.
• Identity of Property: Whether the Court of Appeals erred in finding that the identity of the property subject of ejectment had not been established.
• Nature of the Kasunduan: Whether the Court of Appeals erred in concluding that the document of sale in favor of respondent transferred ownership.

• Scope of Appellate Review: No. The Court of Appeals did not err in considering the identity of the property, as the matter was closely related to the error assigned and its resolution was necessary to arrive at a just decision.
• Identity of Property: No. The CA's factual finding on the lack of identity between the parties' respective properties is binding on the Supreme Court, being a question of fact supported by evidence and not reviewable in a Petition for Review on Certiorari.
• Nature of the Kasunduan: No. The Court of Appeals did not conclude that the Kasunduan transferred ownership; it merely described the lot as having been sold by Bernabe to respondent, which was not inconsistent with the document being a conditional sale at its inception.

• Scope of Appellate Review: Section 8, Rule 51 of the Revised Rules of Court provides that no error will be considered unless stated in the assignment of errors, or closely related to or dependent on an assigned error, save as the court may pass upon plain errors and clerical errors. The Court has consistently held that an appellate court has inherent authority to review unassigned errors when they are closely related to an error properly raised, when the determination of the assigned error is dependent on them, or when their consideration is necessary to arrive at a just decision. The issue raised before the CA was framed broadly — whether the RTC's affirmance of the MeTC decision was proper under the circumstances — and petitioner herself admitted in her Memorandum that the issue was broad enough to cover a range of matters. The identity of the property subject of ejectment was closely related to the assigned error and its resolution was necessary for a just disposition. The CA therefore did not err in tackling the issue.

• Identity of Property: The identity of the subject land is a question of fact, and the CA's finding on this point was supported by evidence. Under established doctrine, factual findings of the Court of Appeals are binding on the Supreme Court and may not be reviewed in a Petition for Review on Certiorari unless those findings are unsupported by the evidence on record. The CA compared the Psu numbers and tax declaration coverage of the respective lots and found they originated from different parent parcels. Petitioner's contention that the CA overlooked her Location Plan was unpersuasive: the Location Plan was not mentioned in her Complaint before the MeTC, nor was it attached to her Motion for Reconsideration or Reply to Comment before the CA. Even assuming the Location Plan had been submitted, lending more credence to one party's evidence does not equate to overlooking the other party's evidence.

• Nature of the Kasunduan: The trial court held that the Kasunduan sa Bilihan ng Lupa embodied a contract to sell or conditional sale, reserving ownership in vendor Bernabe until full payment of the purchase price by installment. The Kasunduan's terms — payment of ₱18,550.00 over twelve years in monthly installments of ₱250.00 — confirmed this characterization. However, the Court of Appeals' statement that the lot was "in turn sold by Bernabe to petitioner Condez" did not necessarily imply that ownership had already transferred at the time of execution. The Court reviewed the CA's assailed decision and resolution and found no basis to conclude that the CA held the Kasunduan to have transferred ownership. The CA's description was not inconsistent with the document being a conditional sale at its inception; ownership could have subsequently transferred upon fulfillment of the suspensive condition. Accordingly, no reversible error was committed.

• Inherent Authority of Appellate Courts to Review Unassigned Errors — An appellate court may review errors not assigned in the appeal when (1) they are closely related to an error properly raised; (2) the determination of the error properly assigned is dependent on them; or (3) their consideration is necessary to arrive at a just decision of the case. The Court applied this doctrine by holding that the identity of the property, though not expressly assigned as error, was closely related to the broad issue of whether the RTC's affirmance was proper and was necessary for a just resolution.
• Binding Nature of CA Factual Findings — Factual findings of the Court of Appeals are conclusive on the parties and are not reviewable by the Supreme Court in a Petition for Review on Certiorari, provided they are supported by the evidence on record. The Court deferred to the CA's factual determination that the parties' lots originated from different parent parcels, as this was a question of fact not subject to review.
• Contract to Sell vs. Contract of Sale — A contract to sell is a form of conditional sale where ownership or title is retained by the vendor until the fulfillment of a positive suspensive condition, normally full payment of the purchase price. The Kasunduan sa Bilihan ng Lupa, providing for installment payments over twelve years, was a contract to sell; however, the CA's reference to the lot as having been "sold" by Bernabe to respondent did not constitute a legal conclusion that ownership had transferred at execution, as transfer could have occurred upon fulfillment of the suspensive condition.

• "Here therefore, the resolution of the assigned error is dependent on the matter of identity of the property subject of ejectment, and the identification of the property is necessary in arriving at a just decision of the case. Thus, we agree that the appellate court did not err in tackling the issue." — This passage states the ratio decidendi on the first issue, affirming the appellate court's authority to consider unassigned but necessary questions.
• "The identity of the subject land is a factual finding supported by evidence, hence, cannot be disturbed in this petition. We are bound by this factual finding of the appellate court, and cannot review again the credibility of witnesses and calibrate the probative value of the evidence on record." — This articulates the doctrine of conclusiveness of CA factual findings in petitions for review on certiorari.
• "One form of conditional sale is what is now popularly termed as a 'Contract to Sell,' where ownership or title is retained until the fulfillment of a positive suspensive condition normally the payment of the purchase price in the manner agreed upon." — This is the canonical formulation of the distinction between a contract of sale and a contract to sell, as quoted from Gomez vs. Court of Appeals.

• Sesbreño vs. Central Board of Assessment Appeals, G.R. No. 106588, March 24, 1997, 270 SCRA 360 — Cited as controlling authority for the proposition that an appellate court has inherent authority to review unassigned errors closely related to assigned errors or necessary for a just decision.
• Towne & City Development Corporation vs. Court of Appeals, G.R. No. 135043, July 14, 2004, 434 SCRA 356 — Cited to distinguish between questions of fact and questions of law, supporting the holding that the identity of the property is a question of fact.
• Gomez vs. Court of Appeals, G.R. No. 120747, September 21, 2000, 340 SCRA 720 — Cited for the doctrinal distinction between a contract of sale and a contract to sell, defining the latter as a conditional sale where title is retained until fulfillment of a suspensive condition.
• St. Michael's Institute vs. Santos, G.R. No. 145280, December 4, 2001, 371 SCRA 383 — Cited for the principle that the Court of Appeals may review matters not assigned as errors when necessary for a just resolution.
• Central Bank of the Philippines vs. Castro, G.R. No. 156311, December 16, 2005, 478 SCRA 235 — Cited for the doctrine that factual findings of the Court of Appeals are binding on the Supreme Court when supported by evidence.

• Section 8, Rule 51, Revised Rules of Court — Provides that no error will be considered unless stated in the assignment of errors, or closely related to or dependent on an assigned error and properly argued in the brief, save as the court may pass upon plain errors and clerical errors. Applied to uphold the CA's authority to review the unassigned issue of property identity, as it was closely related to and dependent on the assigned error.

N/A — The resolution does not identify additional concurring justices beyond the ponente, Justice Quisumbing.

N/A — No dissenting opinions are indicated in the text.