- Petitioner
- Josefina Costales
- Respondent
- Spouses Crisanto
- Citation
- G.R. No. 233384
- Court
- Supreme Court
- Division
- Second Division
- Decided
- November 20, 2017
Summary
This civil case involved a property dispute over Lot 3302 between the Costales family and Spouses Quintinita. The Costales family filed an action for reconveyance claiming 40 years of possession, but failed to adequately identify the property's location, area, and boundaries. Their possession claim was undermined by tax declarations covering only 1994-1998. The Supreme Court affirmed the Court of Appeals' decision denying the reconveyance, applying Article 434 of the Civil Code which requires clear property identification and strong title evidence. The Court emphasized that respondents had superior evidence through a DENR certification showing their predecessor-in-interest as the survey claimant, and reiterated that tax declarations alone cannot defeat certificates of title, serving merely as ownership indicia.