SUPERLINES TRANSPORTATION COMPANY, INC. v.

PHILIPPINE NATIONAL CONSTRUCTION COMPANY

AND PEDRO BALUBAL
519 SCRA 432 (2007), SECOND DIVISION
Superlines Transportation Company, Inc. (Superlines) is engaged in the business of providing public transportation.
One of its buses, while traveling north and approaching the Alabang northbound exit lane, crashed into the radio room
of respondent Philippine National Construction Company (PNCC). PNCC‘s Sofronio Salvanera, and Pedro Balubal,
then head of traffic control and security department of the South Luzon tollway, investigated the incident. The bus was
turned over to the Alabang Traffic Bureau for its own investigation. Because of lack of adequate space, traffic
investigator Pat. Cesar Lopera requested that the bus be towed by the PNCC patrol to its compound. Superlines
made several requests for the release of the bus but Balubal refused. Instead, Balubal demanded the sum of
P40,000.00 or a collateral with the same value for the reconstruction of the damaged radio room.
Superlines filed a replevin suit with damages against PNCC and Balubal before the Regional Trial Court (RTC). The
trial court dismissed the complaint and ordered Superlines to pay PNCC an amount of P40, 320.00, representing
actual damages to the radio room. The Court of Appeals (CA) affirmed the decision and concluded that the case
should have been brought against the police authorities.
ISSUE:
Whether or not a suit for replevin is proper
HELD:
Contrary to PNCC‘s contention, the petition raises questions of law foremost of which is whether the owner of a
personal property may initiate an action for replevin against a depositary and recover damages for illegal distraint. In
a complaint for replevin, the claimant must convincingly show that he is either the owner or clearly entitled to the
possession of the object sought to be recovered, and that the defendant, who is in actual or legal possession thereof,
wrongfully detains the same.
In the case at bar, Superlines‘ ownership of the bus being admitted by PNCC, consideration of whether PNCC has
been wrongfully detaining it is in order. The bus was towed by the PNCC on the request of Lopera in violation
of constitutional right against unreasonable seizures. The seizure and impounding of Superlines‘s bus, on Lopera‘s
request, were unquestionably violative of “the right to be let alone” by the authorities as guaranteed by
the Constitution.
Furthermore, the Supreme Court (SC) finds that it cannot pass upon the same without impleading Lopera and any
other police officer responsible for ordering the seizure and distraint of the bus. The police authorities, through Lopera,
having turned over the bus to PNCC for safekeeping, a contract of deposit was perfected between them and PNCC.
Superlines or the trial court motu proprio may implead as defendants the indispensable parties Lopera and any other
responsible police officers.
SARMIENTO V. CA|CRUZ, 250 SCRA 108

FACTS:
Generosa Cruz owned a parcel of land in Bataan. The adjacent land belongs to the Nuguids but is being used and
occupied by Eufemia Sarmiento for several years now. It was found out by the Geodetic Engineer that Sarmiento’s
fence is encroaching Cruz’s land for about 71 meters. Cruz requested Sarmiento to remove the fence, but the latter
refused so Cruz filed a complaint for ejectment in the Municipal Trial Court.

MTC decided for Cruz. Sarmiento appealed in the RTC, assailing the jurisdiction of the MTC. RTC decided for
Sarmiento and held that the MTC had no jurisdiction to hear the case. CA reversed RTC and reinstated the MTC
decision.

Issue:
Whether or not the court of origin (MTC) had jurisdiction over the ejectment case? (Apparently, Cruz failed to state
details on how the encroachment was done.)

Held:
No. To give the court jurisdiction to effect the ejectment of an occupant or deforciant on the land, it is necessary that
the complaint should embody such statement of facts as brings the party clearly within the class of cases for which the
statutes provide a remedy, as the proceedings are summary in nature. The complaint must show enough on its face to
give the court jurisdiction without resort to parol evidence.

The jurisdictional facts must appear on the face of the complaint. When the complaint fails to aver facts constitutive of
forcible entry or unlawful detainer, as when it does not state how entry was effected or how and when dispossession
started, as in the case at bar, the remedy should either be an accion publiciana or an accion reivindicatoria in the
proper regional trial court.
CARO v. SUCALDITO
G.R. No. 157536; May 16, 2005
Ponente: J. Callejo, Sr.

FACTS:

Gregorio Caro bought a parcel of land known as Assessor's Lot No. 160 from Ruperto Gepilano as evidenced by a
Deed of Sale dated October 21, 1953. The said lot was situated in Sitio Bangyan, Barrio Calaya, Municipality of
Nueva Valencia, Iloilo City, consisting more or less of 17.9849 hectares. Thereafter, Gregorio Caro sold a portion of
the said lot to his son Melchor Caro, consisting of 70,124 square meters, and now identified as Lot No. 4512 of the
Cadastral survey of Nueva Valencia, Pls-775. Father and son executed a Deed of Definite Sale dated January 31,
1973 covering Lot No. 4512.

On August 1, 1974, Melchor Caro applied for a free patent before the Bureau of Lands, District Land Office No. 6-1,
covering the said area of the property which he bought from his father. The application was, however, opposed by
Deogracias de la Cruz. On November 6, 1980, the Regional Director rendered a Decision canceling the said
application.

Caro filed a notice of appeal before the Regional Land Office in Iloilo City, docketed as MNR Case No. 5207.
However, the appeal was dismissed in an Order dated June 29, 1982, on the ground of failure to file an appeal
memorandum within the reglementary period therefor.

On August 29, 1982, Susana R. Sucaldito, as the buyer of Lot No. 4512, filed an Application for a Free Patent
covering the said lot, and was issued Free Patent No. 597599 Thereafter, on February 20, 1984, Caro filed a
Complaint against Sucaldito for "Annulment of Title, Decision, Free Patent and/or Recovery of Ownership and/or
Possession with Damages". He later filed an amended complaint, alleging that he was the owner of the subject lot,
and had been in possession of the same "since 1953 and/or even prior thereto in the concept of owner, adversely,
openly, continuously and notoriously."

Caro further alleged that since the issuance of the free patent over the subject lot in favor of Sucaldito was wrongful
and fraudulent, she had no right whatsoever over the subject lot. Hence, as a "trustee of a constructive trust," she
was obliged to return the same to him as the lawful owner

ISSUE:
Whether Caro has the legal personality to file for the reconveyance of the subject land

HELD:

No, Caro has no legal personality to file for the reconveyance of the subject land.

The Supreme Court ruled that under Section 2, Rule 3 of the Rules of Court, every action must be prosecuted or
defended in the name of the real party-in-interest, or one "who stands to be benefited or injured by the judgment in
the suit." Corollarily, legal standing has been defined as a personal and substantial interest in the case, such that the
party has sustained or will sustain direct injury as a result of the challenged act. Interest means a material interest in
issue that is affected by the questioned act or instrument, as distinguished from a mere incidental interest in the
question involved.

Clearly then, a suit filed by one who is not a party-in-interest must be dismissed. In this case, the petitioner, not being
the owner of the disputed property but a mere applicant for a free patent, cannot thus be considered as a
party-in-interest with personality to file an action for reconveyance.

To reiterate, the petitioner is not the proper party to file an action for reconveyance that would result in the reversion
of the land to the government. The petitioner has no personality to "recover" the property as he has not shown that
he is the rightful owner thereof.