In General Milling Corporation v. Constantino, the Supreme Court addressed the crucial issue of proving damages in cases involving property demolition. The Court reversed the Court of Appeals’ decision, emphasizing that claimants must sufficiently demonstrate their ownership and the actual damages incurred due to the demolition. This ruling underscores the importance of presenting concrete evidence to support claims for damages, particularly in disputes over land and property rights, ensuring that compensation is based on substantiated losses rather than mere allegations.

When Possessory Rights Collide: Proving Ownership in Property Demolition Disputes

The case arose from a dispute over land in Cagayan de Oro City, where General Milling Corporation (GMC) demolished around 200 houses, claiming ownership of the property. The residents, led by Norberto Constantino, filed a complaint seeking damages for the demolition, asserting their long-standing possession of the land. The Regional Trial Court (RTC) initially dismissed the case, siding with GMC. However, the Court of Appeals (CA) reversed this decision, awarding damages to the residents. GMC then appealed to the Supreme Court, questioning the CA’s basis for awarding damages in the absence of concrete evidence from the residents.

At the heart of the legal battle was the issue of whether the residents had adequately proven their right to the property and the extent of the damages they suffered. The Supreme Court emphasized the fundamental principle that in civil cases, the burden of proof lies with the party making the allegations. This means the residents had to demonstrate, through credible evidence, their ownership or rightful possession of the demolished houses and the actual losses they incurred as a result of the demolition. The Court scrutinized the evidence presented by the residents, finding it insufficient to substantiate their claims.

The Supreme Court noted that the residents primarily based their complaint on their alleged possession of the subject lands and their predecessors-in-interest’s possession. However, the Court found that the record lacked sufficient evidence to establish this possession. The testimonies of the two witnesses presented by the residents were deemed insufficient. The Court highlighted that it was not even clarified whether any of the named respondents in the complaint were the homeowners of the demolished structures. The Court also pointed out the absence of documentary evidence, such as pictures or documents, to showcase the kind of houses destroyed or the materials used to construct them, which would have supported their claims for damages.

The Court underscored the necessity of proving ownership of the demolished houses by each of the respondents, not only to provide a basis for the award of damages but also due to the fact that 34 houses remained on the subject land after the initial demolition. The Court reasoned that respondents, to be entitled to damages, should have established that they were not the owners of the houses that remained on the property after the demolition. This point was consistently raised by the petitioner, GMC. The Supreme Court cited the principle that to warrant the recovery of damages, there must be both a right of action for a legal wrong inflicted by the defendant and damage resulting to the plaintiff therefrom. The Court elucidated that a right of action for a legal wrong must coincide with resultant damage to the plaintiff.

Adding to the issue of insufficient proof, the Court noted inconsistencies and weaknesses in the testimonies of the respondents’ witnesses, as observed by the trial court:

x x x To prove their cause of action, plaintiffs presented only two (2) witnesses, in the persons of Primitivo Lucido and Cristina Bajao. Lucido’s testimony contains contradictions on the main point he was testifying the demolition of the houses for while at first, he testified that his house is still existing, he later changed that testimony when asked by the court, that his house was one of those included in the demolition. While he and the other plaintiffs alleged that they had been occupying the area since time immemorial, not a single documentary evidence, either in the form of Tax Declaration or Tax Receipts, was presented to show even a semblance of legality of their occupation of the premises. Lucido’s credibility is put in question because of his vacillating testimony since it is quite clear that his house is still existing. Much less can be said of the testimony of plaintiffs second witness who even admitted that she received payment from defendant and who, after she erected her second house in the area, lost, even on appeal, in the ejection case defendant tiled against her.

The Supreme Court also addressed the issue of nominal damages. The Court explained that nominal damages may be awarded to a plaintiff whose right has been violated or invaded by the defendant, but emphasized that this is for the purpose of vindicating or recognizing that right, not for indemnifying the plaintiff for any loss suffered. In this case, the Court found that it had not been demonstrated that each of the respondents had a right which had been violated or invaded by the defendant. The court held that assuming GMC wrongfully demolished certain houses in the subject land, the same does not automatically warrant an award in favor of respondents.

Moreover, the Supreme Court also reversed the CA’s award of moral damages, citing the personal nature of such damages and the need for the claimant to testify as to the mental anguish, serious anxiety, wounded feelings, and other emotional and mental suffering experienced. As the record was devoid of any such proof or testimony from each claimant, the CA’s award of moral damages was deemed baseless and unwarranted. The Court similarly reversed the grant of exemplary damages, which, according to Articles 2229 and 2234 of the Civil Code, may be awarded only in addition to moral, temperate, liquidated, or compensatory damages. Since the respondents were not entitled to any of these forms of damages, their claim for exemplary damages also failed.

The Supreme Court ultimately concluded that the residents had failed to meet the burden of proving their claims for damages. The Court noted that in the absence of any of the circumstances under Article 2208 of the Civil Code where attorney’s fees may be awarded, the CA’s decision to grant attorney’s fees to respondents was also improper. Consequently, the Supreme Court reversed the Court of Appeals’ decision and dismissed the respondents’ complaint. This case serves as a reminder of the importance of presenting sufficient and credible evidence to support claims for damages in property disputes.

FAQs

What was the key issue in this case?	The key issue was whether the residents adequately proved their right to the property and the damages they claimed to have suffered due to the demolition of their houses.
What did the Supreme Court rule?	The Supreme Court ruled that the residents failed to provide sufficient evidence to support their claims for damages. The Court reversed the Court of Appeals’ decision and dismissed the complaint.
What is the burden of proof in civil cases?	In civil cases, the burden of proof lies with the party making the allegations. This means they must provide sufficient evidence to support their claims.
What type of evidence did the residents lack?	The residents lacked documentary evidence of their ownership or rightful possession of the demolished houses. They also failed to clearly establish that they were the owners of the houses demolished.
Why were the testimonies of the residents’ witnesses deemed insufficient?	The testimonies of the residents’ witnesses were deemed insufficient due to contradictions and a lack of clarity on whether the witnesses were the homeowners of the demolished structures.
What are nominal damages?	Nominal damages are awarded to a plaintiff whose right has been violated, but not to compensate for any loss suffered. It is merely to recognize that a right was violated.
Why were moral and exemplary damages not awarded?	Moral damages were not awarded because the residents did not provide testimony about the mental anguish or emotional suffering they experienced. Exemplary damages were not awarded because they can only be given in addition to other forms of damages, which the residents were not entitled to in this case.
What is the significance of Article 2208 of the Civil Code?	Article 2208 of the Civil Code outlines the circumstances under which attorney’s fees may be awarded. In this case, none of those circumstances were present, so attorney’s fees were not granted.

This case highlights the critical importance of substantiating claims with solid evidence in property disputes. Claimants must demonstrate their rights and the damages they incurred to be entitled to compensation. This ruling reinforces the necessity for thorough preparation and documentation when pursuing legal action related to property demolition and ownership.

For inquiries regarding the application of this ruling to specific circumstances, please contact ASG Law through contact or via email at frontdesk@asglawpartners.com.

Disclaimer: This analysis is provided for informational purposes only and does not constitute legal advice. For specific legal guidance tailored to your situation, please consult with a qualified attorney.
Source: General Milling Corporation v. Constantino, G.R. No. 195919, November 21, 2018