HEIRS OF JUAN OCLARIT v. CA

FACTS:

Juan Oclarit purchased an unregistered land in Bohol for P100 from Macalos. This particular land did not have specified boundaries, as it was only indicated that the borders were a brook, lands of Gales, and another of Baja. He subsequently purchased 5 more unregistered parcels of land from Gales, one of which was an irrigated rice and coconut lands, which is now the subject of the action.

Balasabas apparently entered the land about 15 years later and replaces the J.O. labels on top of the trees with ―F.G.‖ (Felipa Gales, his mother). The heirs of Oclarit then filed an action for the quieting of the title and damages against Balasabas, averring that Oclarit exercised dominion and ownership openly, peacefully, adversely and uninterrupted. The deceased even planted coconut trees and other crops on the land, enjoyed their fruits and even paid realty tax on the land.

RTC initially found for Balasabas after having a Commissioner survey the lands and discovered the discrepancy between the boundaries indicated in the Deed of Sales and the one written on the tax declarations. The CA, however, reversed the decision, and ruled that Oclarit is the rightful owner of the land.

ISSUE:

Whether or not the lands claimed by Balasabas are actually ―foreign and alien‖ to the lands claimed by Oclarit, making these lands actually his property?

HELD:

While it is true that tax declarations are not strong proof to claim one’s property as his, it will stand in court should these tax declarations be coupled with one’s exercise of ownership, such as those proven by Oclarit’s heirs.

Furthermore, although what defines a piece of land is not the area mentioned in its descriptions, but the boundaries laid down, in cases such as this one, where the boundaries are unclear, the actual size of the land gains importance.