CASE DIGESTS-idd (M1-3)

Title: Federation of Coron, Busuanga, Palawan Farmer's Association, Inc. vs.
Secretary of the Department of Environment and Natural Resources

Case G.R. No. 247866
Ponente: GESMUNDO, J
Decision Date: Sep 15, 2020
Legal Principle/ Doctrine: Unclassified lands are not subject to private ownership and
remain part of the inalienable public domain unless the State reclassifies or alienates
them to private persons.
Facts:
The case of Federation of Coron, Busuanga, Palawan Farmer's Association, Inc. v.
Secretary of the Department of Environment and Natural Resources involves the
constitutionality of Section 3 (a) of Presidential Decree (P.D.) No. 705, also known as
the Forestry Reform Code of the Philippines. The petitioners, a group of farmer
associations in Palawan, argue that the provision violates their right to ownership of
unclassified lands and that unclassified lands should be considered as alienable and
disposable land of public domain.
The petitioners, Federation of Coron, Busuanga, Palawan Farmer's Association, Inc.

(FCBPFAI) and Sandigan ng Mambubukid ng Bintuan Coron, Inc. (SAMBICO), are
federations consisting of farmers in Palawan. The farm lands occupied by the members
of SAMBICO in Sitio Dipangan and Langka, Brgy. Bintuan, Coron, Palawan were placed
under the coverage of the Comprehensive Agrarian Reform Program (CARP) by the
Department of Agrarian Reform (DAR). However, the implementation of CARP was
stopped because the lands were classified as unclassified forest land under Sec. 3 (a)
of P.D. No. 705, which means they are inalienable and belong to the government.
Similarly, members of the Samahan ng Magsasaka ng Sto. Nino (SAMMASA) alleged
that the lands they farmed in Brgy. Sto. Nino, Busuanga, Palawan were also classified
as unclassified forest land under Sec. 3 (a) of P.D. No. 705.
Issue:
The main issue raised in the case is whether Section 3 (a) of P.D. No. 705 is
unconstitutional. The petitioners argue that the provision violates the Philippine Bill of
1902 and the 1935, 1973, and 1987 Constitutions. They claim that unclassified lands
should be considered as agricultural land and that the provision retroactively changed
the classification of unclassified lands into forest lands, depriving them of their right to
ownership.
Ruling:
The court ruled that the petition lacks merit. It held that every statute has the
presumption of constitutionality and that the burden of proof is on the petitioner to show
a clear and unequivocal breach of the Constitution. The court also stated that
unclassified lands cannot be considered as alienable and disposable land of public
domain pursuant to the Regalian Doctrine. It explained that the Regalian Doctrine,
which is embodied in the Constitution, states that all lands of public domain belong to
the State. The court further emphasized that even without Section 3 (a) of P.D. No. 705,
unclassified lands are still not subject to private ownership because they belong to the
State and are not alienable and disposable lands of public domain.
Ratio:
The court's ratio is that the regalian doctrine, while often repeated in jurisprudence, is a
legal fiction that has no clear constitutional basis. The court explains that the
presumption that all lands are public and the classification of land as forest or
agricultural depend on the evidence presented in each case. The court also affirms the
validity of native titles to land, recognizing that not all untitled lands are automatically
part of the public domain. The court further states that Section 3(a) of Presidential
Decree No. 705 is in accordance with the regalian doctrine and does not violate due
process. The court emphasizes that the classification of land as forest or agricultural is
a matter of proof and that the presumption in favor of agricultural land can be overcome
by showing the actual nature of the land.
References:
https://jurisprudence.ph/jurisprudence/digest/federation-of-coron-busuanga-palawan-
farmer-s-association-inc-v-secretary-of-the-department-of-environment-and-natural-
resources?q=GR+NO+247866#_
https://www.lawphil.net
Title: Roman Catholic Bishop of Kalibo, Aklan vs. Municipality of Buruanga, Aklan
Case G.R. No. 149145
Ponente: CALLEJO, SR., J
Decision Date: Mar 31, 2006
Legal Principle/ Doctrine: Public Dominion pertain to the State and are held in trust for
the people, for the maintenance of general welfare.
Facts:
The case involves a dispute over the ownership of Lots 138-A and 138-C in Buruanga,
Aklan, Philippines. The Roman Catholic Bishop of Kalibo filed a complaint for
declaration of ownership and quieting of title to land against the Municipality of
Buruanga. The Roman Catholic Bishop of Kalibo claims that it is the lawful owner and
possessor of Lot 138, while the Municipality of Buruanga asserts that it is the rightful
owner of the said lot. The trial court ruled in favor of the Roman Catholic Bishop of
Kalibo with respect to Lot 138-B, but declared Lots 138-A and 138-C as property of
public dominion. The Court of Appeals affirmed the decision of the trial court, declaring
Lots 138-A and 138-C as property of public dominion. The Supreme Court denied the
petition for review on certiorari filed by the Roman Catholic Bishop of Kalibo, affirming
the decision of the Court of Appeals.
Issue:
The main issue in the case is whether Lots 138-A and 138-C are property of public
dominion or owned by the Roman Catholic Bishop of Kalibo.
Ruling:
The Supreme Court ruled that Lots 138-A and 138-C are property of public dominion
and not owned by either the Roman Catholic Bishop of Kalibo or the Municipality of
Buruanga.
Ratio:
The Court based its ruling on the Laws of the Indies, which prescribed the location and
construction of the church and government administration buildings in a town or pueblo.
The Court also considered the lack of evidence showing that the Roman Catholic
Bishop of Kalibo exercised acts of ownership or possession over Lots 138-A and 138-C.
The Court further explained that the case of Roman Catholic Bishop of Jaro v. Director
of Lands, cited by the petitioner, is not applicable to the present case due to significant
factual differences. The Court concluded that the petitioner did not acquire ownership of
Lots 138-A and 138-C by operation of law or government grant, and that the said lots
are property of public dominion.
In summary, the Supreme Court affirmed the decision of the Court of Appeals, declaring
Lots 138-A and 138-C as property of public dominion and not owned by either the
Roman Catholic Bishop of Kalibo or the Municipality of Buruanga. The Court based its
ruling on the Laws of the Indies and the lack of evidence showing the petitioner's
ownership or possession of the said lots.
References:
https://jurisprudence.ph/jurisprudence/digest/roman-catholic-bishop-of-kalibo-aklan-v-
municipality-of-buruanga-aklan?q=G.R.+No.+149145#_
Title: Palanca vs. La Mancomunidad de Filipinas
Case: G.R. No. 46373
Ponente: AVANCEÑA, Pres
Decision Date: Jan 29, 1940
Legal Principle/ Doctrine: Property of public dominion cannot be registered under the
land registration law and be subject to a Torrens title.
Facts:
The case of Palanca v. La Mancomunidad de Filipinas involves the claim of land
ownership by Carlos Palanca, which includes navigable rivers and estuaries. On July
17, 1919, Palanca obtained a judgment from the Court of First Instance of Bulacan for
the registration of four contiguous parcels of land separated only by certain waterways
called esteros. The Government, through the Solicitor General, filed a petition to reopen
the case to prove the existence of navigable rivers and esteros within the land. The
court denied this petition, stating that even if these waterways existed within the land,
their registration would not affect the ownership rights of the Insular Government or the
public use of these communication routes.
Later on, the Government of the Philippines filed an action against Palanca, alleging
that he was illegally occupying portions of the Rio Viray and Estero Sapang Sedaria,
which are navigable, and requested that he be compelled to open them and restore
them to their original state. The trial court dismissed this action, but upon appeal, the
Court of Appeals reversed the decision and declared that the Rio Viray and Estero
Sapang Sedaria are part of the public domain and that Palanca's acquired rights over
the land cannot affect the State's rights over them as public assets.
Issue:
The main issue in this case is whether the Rio Viray and Estero Sapang Sedaria, which
are navigable rivers and esteros, are part of the public domain or owned by Carlos
Palanca.
Ruling:
The Supreme Court denied the appeal and affirmed the decision of the Court of
Appeals. The court upheld that the Rio Viray and Estero Sapang Sedaria are part of the
public domain and not subject to Palanca's claim of ownership.
Ratio:
The Supreme Court based its decision on the evidence presented. It found that the Rio
Viray and Estero Sapang Sedaria are within the land owned by Palanca, as determined
by the judgment of the Court of First Instance of Bulacan. The court also found that
these rivers and esteros are navigable and serve as communication routes between two
bodies of water that flow into Manila Bay. The court further ruled that these waterways
are part of the public domain and are useful for commerce, navigation, and fishing, and
that they had these characteristics even when the land encompassing them still
belonged to the State.
The court rejected Palanca's argument that the previous judgment and Torrens title
establish the non-existence of navigability of the rivers and esteros. It pointed out that
the previous decision did not declare that these esteros were not navigable.
Furthermore, the court emphasized that being navigable rivers and esteros useful for
commerce, navigation, and fishing, they are part of the public domain and their legal
status in this regard is not affected by Palanca's possession, regardless of the length of
time, as prescription does not apply against the State's properties.
In conclusion, the Supreme Court affirmed that the Rio Viray and Estero Sapang
Sedaria are part of the public domain and not subject to Palanca's claim of ownership.
The court emphasized that navigable rivers and esteros are considered public assets
and are not susceptible to prescription.
References:
https://jurisprudence.ph/jurisprudence/digest/palanca-v-la-mancomunidad-de-filipinas?
q=G.R.+No.+46373#_
Title: Manila International Airport Authority vs. Court of Appeals
Case: G.R. No. 155650
Ponente: CARPIO, J
Decision Date: Jul 20, 2006
Legal Principle/ Doctrine: Ports include seaports and airports.
Facts:
The case Manila International Airport Authority v. Court of Appeals involves the Manila
International Airport Authority (MIAA) and the City of Parañaque. MIAA operates the
Ninoy Aquino International Airport (NAIA) Complex and administers the land,
improvements, and equipment within the complex. The MIAA Charter transferred
ownership of the Airport Lands and Buildings to MIAA, but specified that no portion of
the land shall be disposed of unless approved by the President of the Philippines. The
City of Parañaque issued notices of real estate tax delinquency to MIAA, prompting
MIAA to seek clarification from the Office of the Government Corporate Counsel
(OGCC). The OGCC opined that MIAA was no longer exempt from real estate tax under
the Local Government Code of 1991. MIAA then filed a petition to restrain the City of
Parañaque from imposing real estate tax on the Airport Lands and Buildings. The Court
of Appeals dismissed the petition, leading MIAA to file a petition for review with the
Supreme Court.
Issue:
The main issue in this case is whether the Airport Lands and Buildings of MIAA are
exempt from real estate tax under existing laws.
Ruling:
The Supreme Court ruled in favor of MIAA, declaring that the Airport Lands and
Buildings are exempt from real estate tax imposed by local governments.
Ratio:
The Court based its ruling on two main arguments. First, MIAA is not a government-
owned or controlled corporation but an instrumentality of the National Government, and
therefore exempt from local taxation. Second, the Airport Lands and Buildings are
owned by the Republic of the Philippines and considered properties of public dominion,
which are exempt from real estate tax.
The Court explained that MIAA is not a government-owned or controlled corporation

because it is not organized as a stock or non-stock corporation. MIAA is a government
instrumentality vested with corporate powers to perform efficiently its governmental
functions. The Court also emphasized that MIAA is owned solely by the Republic and is
merely holding title to the Airport Lands and Buildings in trust for the Republic.
The Court further clarified that the Airport Lands and Buildings are properties of public
dominion, owned by the State, and therefore exempt from real estate tax. The Court
cited Article 420 of the Civil Code, which defines properties of public dominion as those
intended for public use and those which belong to the State and are intended for public
service or for the development of national wealth. The Court also noted that the Airport
Lands and Buildings are outside the commerce of man and cannot be subject to levy,
encumbrance, or disposition through public or private sale.
In refuting the arguments of the minority, the Court emphasized that Section 133(o) of
the Local Government Code expressly prohibits local governments from imposing any
kind of tax on the National Government, its agencies, and instrumentalities. The Court
also clarified that the definition of "government-owned or controlled corporation" in the
Administrative Code applies to the Local Government Code, unless there is a specific
provision in the latter that defines the phrase differently. The Court further explained that
the phrase "government-owned or controlled corporation" applies to both corporations
organized under the Corporation Code and those created by special charters. The Court
emphasized that the test of economic viability applies only to government-owned or
controlled corporations that perform economic or commercial activities and need to
compete in the market place. On the other hand, government instrumentalities vested
with corporate powers and performing governmental or public functions do not need to
meet the test of economic viability. The Court concluded that MIAA, as a government
instrumentality, is exempt from real estate tax under Section 133(o) of the Local
Government Code.
Reference:
https://jurisprudence.ph/jurisprudence/digest/manila-international-airport-authority-v-
court-of-appeals-10025?q=G.R.+No.+155650#_
Title: Cebu Oxygen & Acetylene Co., Inc. vs. Bercilles
Case: G.R. No. L-40474
Ponente: CONCEPCION, JR., J
Decision Date: Aug 29, 1975
Legal Principle/ Doctrine: Patrimonial property is within the commerce of men and can
be acquired through prescription and be the subject of contracts.
Facts:
The case of Cebu Oxygen & Acetylene Co., Inc. v. Bercilles involves the application for
registration of title over a portion of M. Gorces Street in Cebu City. The petitioner, Cebu
Oxygen & Acetylene Co., Inc., sought to register the said portion as private property.
The City Council of Cebu declared the terminal portion of M. Borces Street as an
abandoned road, as it was not included in the City Development Plan. Subsequently,
the City Council authorized the Acting City Mayor to sell the land through a public
bidding, and the petitioner emerged as the winning bidder. The City of Cebu executed a
deed of absolute sale in favor of the petitioner. However, the Assistant Provincial Fiscal
filed a motion to dismiss the application, arguing that the property sought to be
registered is considered part of the public domain and therefore cannot be subject to
registration by a private individual. The trial court dismissed the application, leading the
petitioner to file a petition for review with the Supreme Court.
Issue:
The main issues raised in the case are: (1) Does the City Charter of Cebu City give the
City of Cebu the valid right to declare a road as abandoned? and (2) Does the
declaration of the road as abandoned make it the patrimonial property of the City of
Cebu which may be the object of a common contract?
Ruling:
The Supreme Court ruled in favor of the petitioner. It held that the City of Cebu is
empowered to close a city road or street, as stated in the Revised Charter of Cebu City.
The court cited the case of Favis vs. City of Baguio, where a similar power of the city
council to close city streets was upheld. The court emphasized that the city council is
the authority competent to determine whether a certain property is still necessary for
public use. Therefore, the withdrawal of the portion of the city street from public use is
valid. Additionally, the court stated that when property of public dominion is no longer
intended for public use, it becomes part of the patrimonial property of the State, as
provided in Article 422 of the Civil Code. The Revised Charter of the City of Cebu also
explicitly states that property withdrawn from public servitude may be used or conveyed
for any purpose for which other real property belonging to the City may be lawfully used
or conveyed. Thus, the court concluded that the petitioner has a registerable title over
the lot in question.
Ratio:
The Supreme Court's decision was based on the powers granted to the city council
under the City Charter and the provision in the Civil Code regarding property of public
dominion. The court recognized the authority of the city council to declare a road as
abandoned and to determine whether a certain property is still necessary for public use.
It also acknowledged that when property of public dominion is no longer intended for
public use, it becomes part of the patrimonial property of the State. The court further
relied on the explicit provision in the Revised Charter of the City of Cebu, which allows
property withdrawn from public servitude to be used or conveyed for any purpose for
which other real property belonging to the City may be lawfully used or conveyed.
Based on these legal principles, the court concluded that the petitioner has a valid
registerable title over the portion of the road in question.
Reference:
https://jurisprudence.ph/jurisprudence/digest/cebu-oxygen-acetylene-co-inc-v-bercilles?
q=G.R.+No.+l-40474#_
Title: Balbin vs. Medalla
Ponente: DE CASTRO, J
Decision Date: Oct 30, 1981
Legal Principle/ Doctrine: The validity of the possessory information title only requires
the institution of a possessory information proceeding within the one-year period
provided in the Maura Law.
Facts:
The case of Balbin v. Medalla involves a dispute over the ownership of a parcel of
agricultural land in Occidental Mindoro, Philippines. The private respondents, Pedro C.
Medalla and Josefina Medalla, purchased the land from the heirs of Juan Ladao and
applied for registration and titling of the land in their name. However, the petitioners,
Ernesto Balbin and others, opposed the application on the grounds that they already
held Original Certificates of Titles over the same properties through homestead or free
patent grants. The Land Registration Court abstained from ruling on the opposition, as
the Medallas reserved the right to file a separate action for the cancellation of the titles
issued to the petitioners.
The court a quo (Court of First Instance of Occidental Mindoro) rendered a judgment
declaring the lands as private properties of the Medallas based on a registered
Informacion Pasesoria in the name of Juan Ladao, from whom they purchased the
properties. The court also declared the free patents and corresponding titles of the
petitioners null and void and ordered their cancellation. The petitioners appealed the
decision, arguing that the possessory information titles of the Medallas' predecessor-in-
interest were invalid and that the Medallas' cause of action had already prescribed.
Issue:
The main issues raised in the case are:
Whether the possessory information titles of the Medallas' predecessor-in-interest were

valid.
Whether the Medallas' cause of action had already prescribed.
Ruling:
The Supreme Court ruled in favor of the petitioners.
Ratio:
The court held that for the validity of a possessory information title, only the institution of
a possessory information proceeding within the one-year period provided in the Maura
Law is required. In this case, the registration of the possessory information in the name
of Juan Ladao on January 25, 1895, followed the institution of a possessory information
proceeding within the period provided by the decree. Therefore, the registration was
valid.
Regarding the issue of prescription, the court held that any action for reconveyance
should have been commenced within four years from the discovery of the alleged fraud.
As the latest patent was issued on October 14, 1959, any action for reconveyance
should have been filed on or before October 14, 1963. Since the Medallas' action was
filed more than 14 years after the issuance of the petitioners' titles, their action for
reconveyance had already prescribed.
The court further held that the petitioners had acquired title to the lots in question by
virtue of possession in concept of owners. The possessory information title, which was
the basis of the Medallas' claim of ownership, was deemed ineffective as a mode of
acquiring title under Act 496 without a showing of actual, public, and adverse
possession of the land for a sufficient period of time. The Torrens titles issued to the
petitioners on the basis of their homestead and free patents had become indefeasible,
and they had acquired a better right to the land in question.
In conclusion, the Supreme Court ruled in favor of the petitioners, declaring their
homestead and free patents as valid and dismissing the Medallas' claim of ownership
based on a possessory information title, which was deemed ineffective due to lack of
actual, public, and adverse possession.
Reference:
https://jurisprudence.ph/jurisprudence/digest/balbin-v-medalla?q=G.R.+No.+l-46410#_
Title: Balbin vs. Medalla CRISANTA GUIDO-ENRIQUEZ, Petitioner, v. ALICIA I.
VICTORINO, HEIRS OF ANTONIA VDA. DE VICTORINO, AND HON. RANDY A.
RUTAQUIO, IN HIS CAPACITY AS ACTING REGISTER OF DEEDS OF RIZAL FOR
MORONG BRANCH, Respondents.
Case: G.R. No. 180427
Ponente: PERALTA, J.
Decision Date: September 30, 2013
Legal Principle/ Doctrine: In land registration proceedings, being in rem, there is no

necessity to give personal notice to the owners or claimants of the land sought to be
registered in order to vest the courts with power and authority over the res.
Facts:
Petition for review on Certiorari seeking to reverse and set aside the Decision and
Resolution ofthe Court of Appeals dated September 6, 2007 and October 25, 2007,
respectively, which upheld thedecision of the RTC-Pasig granting respondent’s Motion
for issuance of a decree of registration in her favor of the subject lot.
On February 1980, Antonia Victorino, respondent’s predecessor-in-interest, filed an

application for the registration of title with the CFI of Rizal alleging that she is the owner
of the subject lot which she acquired thru purchase with her husband and that they have
been in open, continuous, exclusive, notorious, and adverse possession and occupation
of the said lot. The application was opposed by the Republic as the subject lot belongs
to the state and is not subject for private appropriation. The RTC-Pasig granted
Victorino’s application but the decree was held in abeyance by the LRA pending
resolution of the Guido case.
It was alleged that RTC Decision granting the application should be nullified since
Antonia Victorino did not identify petitioner as an occupant or an adjoining owner which
is tantamount to denial of due process.
Issue:
Whether or not there was denial of petitioner's right to due process due to Antonia
Victorino's failure to identify petitioner as indispensable party in her application for
registration, as well as to serve her with actual and personal notice.
Ruling:
This Court has already ruled that in land registration proceedings, being in rem, there is
no necessity to give personal notice to the owners or claimants of the land sought to be
registered in order to vest the courts with power and authority over the res.15 Moreover,
since no issue was raised as to Antonia Victorino's compliance with the prerequisites of
notice and publication, she is deemed to have followed such requirements. As a
consequence, petitioner is deemed sufficiently notified of the hearing of Antonia's
application. Hence, she cannot claim that she is denied due process.
Reference:
https://chanrobles.com/cralaw/2013septemberdecisions.php?id=790
Title: Gomez vs. Court of Appeals
Ponente: PADILLA, J
Decision Date: Dec 15, 1988
Legal Principle/ Doctrine: The duty of the land registration officials to issue the
decrees is not purely ministerial.
Facts:
The case of Gomez v. Court of Appeals involves a dispute over the registration of lots in
Bayambang, Pangasinan. The petitioners, who are the heirs of Teodoro Y. Gomez, filed
an application for registration of several lots in the Court of First Instance (now Regional
Trial Court) of San Carlos City, Pangasinan. These lots were previously involved in a
case where the Supreme Court declared Consolacion M. Gomez as the owner of
certain lots in Sitio Poponto, Bayambang, Pangasinan. After the death of Teodoro
Gomez, the petitioners became the absolute owners of the lots by virtue of a Quitclaim
executed in their favor by Luis Lopez, Consolacion's son. The trial court issued a
decision on August 5, 1981, adjudicating the lots in favor of the petitioners. The court
also issued an order on October 6, 1981, stating that the decision had become final and
directing the issuance of decrees of registration. However, respondent Silverio G.
Perez, Chief of the Division of Original Registration, Land Registration Commission,
submitted a report stating that the lots were already covered by homestead patents
issued in 1928 and 1929. As a result, the lower court set aside the decision and order
for the issuance of decrees.
Issue:
The main issue in this case is whether the decision of the lower court, adjudicating the
lots in favor of the petitioners, had already become final and whether the lots, which
were already covered by homestead patents, can still be the subject of another
registration.
Ruling:
The Supreme Court affirmed the decision of the Court of Appeals, stating that the
decision of the lower court had not yet become final and that land already granted by
homestead patent cannot be the subject of another registration.
Ratio:
The Court held that the adjudication of land in a registration proceeding does not
become final until after the expiration of one year from the entry of the final decree of
registration. In this case, the decision of the lower court was issued on August 5, 1981,
but the order for the issuance of decrees was made on October 6, 1981. Therefore, the
decision had not yet become final at the time the report of respondent Perez was
submitted, which stated that the lots were already covered by homestead patents.
The Court also emphasized that the duty of the land registration officials to issue the
decree is ministerial, but they may refer any doubts to the court. In this case, the land
registration officials properly referred the matter to the court when they discovered that
the lots were already covered by homestead patents.
Furthermore, the Court clarified that the lots in question were not included in the lands
adjudicated to Consolacion Gomez in a previous case. Therefore, the petitioners cannot
claim ownership of the lots based on their inheritance from Teodoro Gomez, who
inherited the parcels of land from Consolacion Gomez.
Based on these reasons, the Court denied the petition and affirmed the decision of the
Court of Appeals.
Reference:
https://jurisprudence.ph/jurisprudence/digest/gomez-v-court-of-appeals-21495?q=G.R.
+No.+77770#_
Title: Heirs of Soriano vs. Court of Appeals
Case: G.R. No. 128177
Ponente: YNARES-SANTIAGO, J
Legal Principle/ Doctrine: Possession and ownership are distinct legal concepts, and
while the ownership of the land has been confirmed with finality, the right of possession
is still being contested; The rights of agricultural tenants to security of tenure and stated
that the exercise of the right of ownership yields to the exercise of the rights of an
agricultural tenant.
Facts:
The case of Heirs of Soriano v. Court of Appeals involves a dispute over the possession
of a property between the Heirs of Soriano and the spouses Abalos. The property in
question was originally leased by the Heirs of Adrian Soriano to the De Vera spouses,
with Roman Soriano, one of the heirs, acting as caretaker. The heirs later subdivided
the property into two lots, Lot No. 60052 and Lot No. 8459. In 1971, the heirs sold Lot
No. 60052 and their three-fourth shares in Lot No. 8459 to the spouses Abalos. Roman
Soriano, who had been ousted as caretaker, filed a case for reinstatement and
reliquidation against the De Vera spouses. The agrarian court ordered the ejectment of
Roman Soriano, but this decision was reversed by the Court of Appeals.
Prior to the execution of the decision, the parties entered into a post-decisional
agreement that allowed Roman Soriano to sub-lease the property until the termination
of the lease. In 1976, the spouses Abalos filed an application for registration of title over
the lots they purchased. The application was granted in 1983, but a day after the
decision was issued, Roman Soriano, along with two other heirs, filed a civil case
against the spouses Abalos for annulment of document and/or redemption, ownership,
and damages. The spouses Abalos filed a motion to dismiss the case on the ground of
res judicata, but it was denied. The spouses Abalos were then required to file their
answer. On appeal, the Supreme Court reversed the denial and ordered the dismissal of
the annulment case.
In 1993, the Heirs of Roman Soriano filed a complaint with the Department of Agrarian
Reform and Adjudication Board (DARAB) against the spouses Abalos for "Security of
Tenure with prayer for Status Quo Order and Preliminary Injunction." Meanwhile, the
spouses Abalos moved in the registration case for the issuance of an alias writ of
execution and/or writ of possession. The land registration court held the motion in
abeyance until after the complaint of the heirs for security of tenure has been received
by the DARAB. However, the Court of Appeals set aside the resolution of the land
registration court and ordered the issuance of the writ of possession in favor of the
spouses Abalos.
Issue:
The main issue in this case is whether a winning party in a land registration case can
effectively eject the possessor of the land, whose security of tenure rights are still
pending determination before the DARAB.
Ruling:
The Supreme Court ruled that a judgment in a land registration case cannot be used to
oust the possessor of the land whose security of tenure rights are still pending
determination before the DARAB. The court emphasized that possession and
ownership are distinct legal concepts, and while private respondents have been
declared titled owners of the land, their exercise of ownership rights is subject to
limitations imposed by law, such as the security of tenure rights of agricultural tenants.
The court held that the prevailing party in a land registration case cannot be placed in
possession of the land while it is being occupied by one claiming to be an agricultural
tenant, pending a declaration that the latter's occupancy was unlawful.
Ratio:
The Supreme Court based its ruling on the distinction between possession and
ownership. It held that possession and ownership are separate legal concepts, and
while the spouses Abalos have been declared titled owners of the land through the land
registration case, their exercise of ownership rights is subject to limitations imposed by
law. In this case, the security of tenure rights of the agricultural tenants, represented by
the Heirs of Roman Soriano, are still pending determination before the DARAB.
Therefore, the court concluded that the prevailing party in a land registration case
cannot be placed in possession of the land while it is being occupied by one claiming to
be an agricultural tenant, pending a declaration that the latter's occupancy was unlawful.
Based on this reasoning, the Supreme Court set aside the decision of the Court of
Appeals and reinstated the resolution of the land registration court, which held the
motion for the issuance of the writ of possession in abeyance until the complaint for
security of tenure has been resolved by the DARAB.
Reference:
https://jurisprudence.ph/jurisprudence/digest/heirs-of-soriano-v-court-of-appeals?q=
%E2%80%A2%09Heirs+of+Roman+Soriano+v.+Court+of+Appeals%2C+G.R.+No.
+128177%2C+August+15%2C+2001#_
Title: Custodio vs. Corrado
Case: G.R. No. 146082
Ponente: QUISUMBING, J
Legal Principle/ Doctrine: To establish a tenancy relationship, the alleged tenant must
prove the existence of the essential elements of tenancy, such as consent of the
landowner, payment of rent, and the agreement to cultivate or occupy the land.
Facts:
The case involves a dispute over possession and ownership of a residential lot in
Batangas, Philippines. The petitioner, Melchor Custodio, and the respondent, Rosendo
F. Corrado, are the parties involved in the case. The case was initially filed by Corrado
against Custodio in the Municipal Trial Court (MTC) of Calatagan, Batangas, but was
dismissed on the grounds of lack of jurisdiction, failure to undergo barangay conciliation,
and lack of evidence. Corrado then filed another complaint for recovery of possession
and damages against Custodio in the same MTC, which is the subject of the present
petition.
Corrado claims to be the registered owner of the residential lot and alleges that
Custodio, without his knowledge and consent, demolished his old residential house on
the lot and constructed a new one where Custodio and his family now reside. Custodio,
on the other hand, claims to be a legitimate leasehold tenant of Corrado's father and
that the construction of the house was with the consent of Corrado's father.
During the pre-trial conference, the parties agreed on several stipulations of facts,
including that Custodio has never been a tenant of Corrado, and that the construction of
the house was without Corrado's consent. The MTC initially ruled in favor of Custodio,
finding that he had a factual and legal basis for his continued stay on Corrado's property
as a tenant of Corrado's father. However, the RTC reversed the MTC's decision,
declaring Corrado as the true and absolute owner of the lot and ordering Custodio to
deliver possession to Corrado. The Court of Appeals affirmed the RTC's decision.
Issue:
The main issues raised in the case are: (1) whether the principle of res judicata is
applicable, and (2) whether the alleged tenancy relationship between Custodio and
Corrado's father was established by preponderance of evidence.
Ruling:
The Supreme Court ruled that the principle of res judicata is not applicable in this case
because the judgment in the previous case was not on the merits and there is no
identity of causes of action between the two cases. The Court also found that the
alleged tenancy relationship was not established by preponderance of evidence, as the
milling tickets presented as evidence did not prove that they referred to the subject lot in
question. The Court affirmed the decisions of the lower courts, declaring Corrado as the
true and absolute owner of the lot and ordering Custodio to deliver possession to
Corrado.
Ratio:
The principle of res judicata, which means "a matter already judged," applies when a
final judgment on the merits has been rendered by a court of competent jurisdiction and
the same parties, subject matter, and cause of action are involved in a subsequent
case. In this case, the previous judgment dismissing the case against Custodio was not
on the merits and was based on procedural grounds. Furthermore, the causes of action
in the two cases are not identical, as the first case involved jurisdictional and evidentiary
issues, while the second case involves the recovery of possession and damages.
Therefore, the principle of res judicata does not apply.
To establish a tenancy relationship, the alleged tenant must prove the existence of the
essential elements of tenancy, such as consent of the landowner, payment of rent, and
the agreement to cultivate or occupy the land. In this case, Custodio failed to present
sufficient evidence to prove that he was a tenant of Corrado's father. The milling tickets
presented as evidence did not establish a connection to the subject lot in question.
Therefore, the alleged tenancy relationship was not proven by preponderance of
evidence.
Based on these findings, the Supreme Court affirmed the decisions of the lower courts,
deliver possession to Corrado.
In summary, the Supreme Court ruled against Custodio and in favor of Corrado, finding
that the principle of res judicata is not applicable and that the alleged tenancy
relationship was not proven. The Court affirmed the decisions of the lower courts,
deliver possession to Corrado.
Reference:
https://jurisprudence.ph/jurisprudence/digest/custodio-v-corrado?q=G.R.+No.
+146082%2C+July+30%2C+2004#_
Title: Heirs of Cullado vs. Gutierrez
Case: G.R. No. 212938
Ponente: CAGUIOA, J
Legal Principle/ Doctrine: Rights in ownership includes the right to recover; The
resolution of the issue of ownership in an accion publiciana is provisional and does not
constitute a direct or collateral attack on a Torrens title.
Facts:
The case of Heirs of Cullado v. Gutierrez involves a dispute over a parcel of land in
Isabela, Philippines. The land was originally awarded to Dominic Gutierrez through a
land title issued in 1995. However, the heirs of Alfredo Cullado, who claimed to have
been in possession of the land since 1977, filed an action for recovery of ownership and
possession against Gutierrez. They alleged that Gutierrez fraudulently obtained the land
title and requested for its reconveyance.
During the trial, Cullado passed away and was substituted by his heirs. Gutierrez's
counsel repeatedly failed to attend the scheduled hearings, leading to the heirs of
Cullado being allowed to present their evidence. The Regional Trial Court (RTC)
eventually rendered a decision in favor of the heirs of Cullado, ordering the dismissal of
Gutierrez's complaint and the reconveyance of the land to the heirs.
Issue:
The main issue before the Supreme Court was whether the Court of Appeals (CA) erred
in reversing the RTC's decision and granting Gutierrez's petition for annulment of
judgment.
Ruling:
The Court first addressed the propriety of Gutierrez's availment of the remedy of
annulment of judgment. It held that the remedy can only be availed of when ordinary
remedies are no longer available through no fault of the petitioner. In this case,
Gutierrez had already filed a petition for relief from judgment, raising the issue of
extrinsic fraud, which barred him from raising the same issue in his petition for
annulment of judgment. However, the Court ruled that Gutierrez could still raise the
ground of lack of jurisdiction, as he immediately resorted to court action upon learning of
the unfavorable decision.
The Court then discussed the nature of an accion publiciana, which is an ordinary civil
proceeding to determine the better right of possession of real property independently of
title. It clarified that the resolution of the issue of ownership in an accion publiciana is
provisional and does not constitute a collateral attack on a Torrens title. The Court
emphasized the importance of the Torrens system in protecting land titles and held that
the RTC exceeded its jurisdiction in ordering the reconveyance of the land. It affirmed
the CA's decision, ruling in favor of Gutierrez and ordering the heirs of Cullado to vacate
and surrender the land to him.
The Court also noted that the ruling in this case is limited to the issue of determining the
better right to possession and is not a final and binding determination of ownership. It
stated that the parties or even third persons are still free to file an action for the
determination of ownership.
Ratio:
The Court held that Gutierrez's petition for annulment of judgment was not proper, as he
had already filed a petition for relief from judgment raising the issue of extrinsic fraud.
However, the Court allowed Gutierrez to raise the ground of lack of jurisdiction, as he
immediately resorted to court action upon learning of the unfavorable decision.
The Court clarified that an accion publiciana is an ordinary civil proceeding to determine
the better right of possession of real property independently of title. It emphasized that
the resolution of the issue of ownership in an accion publiciana is provisional and does
not constitute a collateral attack on a Torrens title. The Court held that the RTC
exceeded its jurisdiction in ordering the reconveyance of the land and affirmed the CA's
decision in favor of Gutierrez.
The Court also emphasized that the ruling in this case is limited to the issue of
determining the better right to possession and is not a final and binding determination of
ownership. It stated that the parties or even third persons are still free to file an action
for the determination of ownership.
Reference:
https://jurisprudence.ph/jurisprudence/digest/heirs-of-cullado-v-gutierrez?q=G.R.+No.
+212938%2C+July+30%2C+2019#_
Title: Diamond Farms, Inc. vs. Diamond Farm Workers Multi-Purpose Cooperative
Case: G.R. No. 192999
Ponente: VILLARAMA, JR., J
Legal Principle/ Doctrine: Rights in ownership includes the rights to production share
and interest.
Facts:
The case of Diamond Farms, Inc. v. Diamond Farm Workers Multi-Purpose Cooperative
involves a dispute over land ownership between Diamond Farms, Inc., a corporation
engaged in commercial farming, and Diamond Farm Workers Multi-Purpose
Cooperative, a cooperative of agrarian reform beneficiaries. Diamond Farms, Inc.
owned a large portion of land in Carmen, Davao, which was initially deferred for
acquisition and distribution under the Comprehensive Agrarian Reform Program
(CARP). However, on February 14, 1995, the Deferment Order was lifted and a portion
of the land was placed under CARP coverage and awarded to members of the Diamond
Agrarian Reform Beneficiaries Multi-Purpose Cooperative (DARBMUPCO). The
petitioner maintained management and control of another portion of the land.
Issue:
The main issues raised in the case were: (1) whether the respondents were guilty of
unlawful occupation and liable for damages and attorney's fees, (2) whether the
petitioner should turn over possession of the land to the respondents, and (3) whether
the award of production share and interest was proper.
Ruling:
The Supreme Court ruled in favor of the respondents, affirming the decisions of the
DARAB and CA. The Court held that the respondents were not guilty of unlawful
occupation and that the petitioner should turn over possession of the land to them. The
Court also upheld the award of production share and interest, stating that the
respondents were entitled to it based on the CARL and the approved Production and
Profit Sharing (PPS) Scheme. The Court emphasized that the issue of just
compensation was not raised in the case and that the determination of just
compensation is within the jurisdiction of the Regional Trial Court acting as a Special
Agrarian Court.
Ratio:
The Supreme Court based its decision on the provisions of the Comprehensive Agrarian
Reform Law (CARL) and the approved Production and Profit Sharing (PPS) Scheme.
The Court held that the respondents, as agrarian reform beneficiaries, were entitled to
the land awarded to them under CARP. The Court also emphasized that the issue of just
compensation was not raised in the case and that the determination of just
compensation is within the jurisdiction of the Regional Trial Court acting as a Special
Agrarian Court. Therefore, the Court affirmed the decisions of the lower courts, ordering
the turnover of the land to the respondents and upholding the award of production share
and interest.
In conclusion, the Supreme Court ruled in favor of the Diamond Farm Workers Multi-
Purpose Cooperative, ordering the turnover of the land to them and affirming the award
of production share and interest. The Court also directed the Department of Agrarian
Reform and the Provincial Agrarian Reform Officer to assist in the distribution of the
land to the qualified agrarian reform beneficiaries.
Reference:
https://jurisprudence.ph/jurisprudence/digest/diamond-farms-inc-v-diamond-farm-
workers-multi-purpose-cooperative?q=G.R.+No.+192999%2C+July+18%2C+2012#_
Title: Andamo vs. Intermediate Appellate Court
Ponente: FERNAN, J
Decision Date: Nov 6, 1990
Legal Principle/ Doctrine: The use of one's property is not without limitations; Article
431 of the Civil Code provides that every owner must so use his property as not to
injure the rights of others; The construction of waterpaths and contrivances by the
respondent corporation caused damage to the adjacent land, which is a violation of the
duty to use one's property without causing harm to others.
Facts:
This case involves a dispute between petitioner spouses Emmanuel and Natividad
Andamo and respondent Missionaries of Our Lady of La Salette, Inc. The petitioners
own a parcel of land adjacent to the land owned by the respondent corporation. The
petitioners allege that the respondent corporation constructed waterpaths, water
conductors, and contrivances within its land, which caused inundation, erosion, and
damage to the petitioners' land. The construction also allegedly resulted in the drowning
of a young man, damage to crops and plants, destruction of fences, and endangerment
of lives during rainy and stormy seasons.
The petitioners filed a criminal case against the officers and directors of the respondent
corporation for destruction by means of injunction. They also filed a civil case for
damages against the respondent corporation. The trial court suspended the civil case
pending the resolution of the criminal case. The trial court eventually dismissed the civil
case for lack of jurisdiction, citing the provision of the Rules of Court that prohibits the
institution of a civil action until final judgment has been rendered in the related criminal
action. The dismissal was affirmed by the Intermediate Appellate Court.
Issue:
The main issue in this case is whether the dismissal of the civil case was proper.
Ruling:
The Supreme Court agrees with the petitioners and reverses the decision of the
Intermediate Appellate Court.
Ratio:
The Supreme Court explains that the nature of an action is determined by the facts
alleged in the complaint. In this case, the petitioners' complaint alleges all the elements
of a quasi-delict, namely damages suffered by the plaintiffs, fault or negligence of the
defendant, and the connection of cause and effect between the fault or negligence and
the damages. The Court emphasizes that the use of one's property is not without
limitations and that adjoining landowners have mutual and reciprocal duties to use their
land in a reasonable manner so as not to infringe upon the rights and interests of
others. The Court concludes that the respondent corporation can be held civilly liable for
the damages caused by the construction of the waterpaths and contrivances.
The Court also clarifies that the civil action for quasi-delicts is entirely independent of
the criminal case. The acquittal or conviction in the criminal case is irrelevant in the civil
case, unless the court declares that the fact from which the civil action arose did not
exist. The Court cites previous decisions to support this distinction between civil liability
arising from a crime and responsibility for quasi-delicts.
Therefore, the Supreme Court orders the reinstatement of the civil case and directs the
trial court to proceed with the hearing of the case. The decision is immediately
executory.
Reference:
https://jurisprudence.ph/jurisprudence/digest/andamo-v-intermediate-appellate-court?
q=G.R.+No.+74761%2C+November+6%2C+1990#_
Title: Bachrach Motor Co., Inc. vs. Talisay-Silay Milling Co.
Ponente: ROMUALDEZ, J
Legal Principle/ Doctrine: The bonus payment was not a civil fruit of the mortgaged
property; The bonus payment was not derived from the mortgaged property, but rather
served as compensation for the risk of subjecting one's land to a lien in favor of the
bank.
Facts:
The case of Bachrach Motor Co., Inc. v. Talisay-Silay Milling Co. involves a dispute over
a bonus payment to planters. The Talisay-Silay Milling Co., Inc. had to pay the planters
who had mortgaged their lands to the Philippine National Bank in order to secure the
payment of the company's debt to the bank. The Philippine National Bank claimed a
preferential right to receive the bonus payment, arguing that it is considered a civil fruit
of the mortgaged property.
Issue:
The main issue raised in the case is whether the bonus payment to the planters is
considered a civil fruit of the mortgaged property.
Ruling:
The court ruled that the bonus payment is not a civil fruit of the mortgaged property.
Ratio:
According to Article 355 of the Civil Code, civil fruits are considered to be rents from
buildings, proceeds from leases of lands, and income from perpetual or life annuities or
similar sources of revenue. The court interpreted the phrase "u otras analogas" in the
law to refer only to rents or income, and not to the bonus payment. The bonus payment
is not derived from the mortgaged property, but rather serves as compensation for the
risk of subjecting one's land to a lien in favor of the bank. Therefore, the court denied
the Philippine National Bank's preferential right to receive the bonus payment.
In summary, the court ruled that the bonus payment to the planters is not considered a
civil fruit of the mortgaged property. The court based its decision on the interpretation of
Article 355 of the Civil Code, which defines civil fruits as rents from buildings, proceeds
from leases of lands, and income from perpetual or life annuities or similar sources of
revenue. Since the bonus payment is not derived from the mortgaged property, the
Philippine National Bank does not have a preferential right to receive it.
Reference:
https://jurisprudence.ph/jurisprudence/digest/bachrach-motor-co-inc-v-talisay-silay-
milling-co?q=G.R.+No.+35223+#_
Title: Ignao vs. Intermediate Appellate Court
Ponente: FERNAN, C.J
Decision Date: Jan 18, 1991
Legal Principle/ Doctrine: Article 448 of the Civil Code provides for the rights of the
landowner and the builder in good faith; When co-ownership is terminated by partition
and a house built in good faith encroaches upon another co-owner's portion, Article 448
determines the respective rights of the parties; The right to appropriate the works or
improvements or to oblige the builder to pay the price of the land belongs to the
landowner.
Facts:
The case of Ignao v. Intermediate Appellate Court involves a dispute over a land
partition. The petitioner, Florencio Ignao, and the respondents, Juan Ignao and Isidro
Ignao, were co-owners of a parcel of land in Cavite. In a previous decision, the Court of
First Instance of Cavite ordered the partition of the land, allocating a portion to each
party. However, no actual partition was ever carried out.
Subsequently, Florencio filed a complaint for recovery of possession of the real property
against Juan and Isidro, alleging that the houses they built on their allotted portion
exceeded the area specified in the partition decision. An ocular inspection confirmed
that the houses encroached upon Florencio's land. A survey determined that Juan's
house occupied 42 square meters and Isidro's house occupied 59 square meters of
Florencio's land, totaling 101 square meters.
Issue:
The main issues raised in the case are:
Whether Article 448 or Article 486 of the Civil Code should apply in determining the
rights of the parties.
Whether the court erred in ordering Florencio to sell the land to Juan and Isidro without
giving him the right to choose.
Ruling:
The Supreme Court ruled in favor of Florencio on the second assigned error. The Court
held that the trial court and the Appellate Court erred in ordering Florencio to sell the
land to Juan and Isidro without giving him the right to choose. The Court emphasized
that Article 448 confers the right of choice upon the landowner, not the builder or the
courts. Therefore, the Court modified the decision and directed Florencio to exercise his
option within 30 days to either appropriate the portions of the houses upon payment of
indemnity or sell the occupied land to the respondents at an agreed-upon price. If the
value of the land exceeds the value of the houses, the respondents may choose not to
buy the land but must pay reasonable rent. If there is disagreement, the trial court will
determine the rental rate and other terms of the lease. Alternatively, the respondents
may remove or demolish the encroaching portions of their houses at their own expense.
Ratio:
The Court based its decision on the interpretation of Article 448 of the Civil Code. Article
448 grants the owner of the land the right to appropriate the works or oblige the builder
to pay the price of the land. The Court emphasized that this right of choice is given to
the landowner, not the builder or the courts. Therefore, the trial court and the Appellate
Court erred in ordering Florencio to sell the land to Juan and Isidro without giving him
the right to choose.
The Court also considered the practicality of exercising the option to appropriate the
portions of the houses. It noted that doing so would render the houses worthless. In light
of this, the Court modified the decision and provided alternative options for Florencio
and the respondents. Florencio was given the option to either appropriate the portions
of the houses upon payment of indemnity or sell the occupied land to the respondents
at an agreed-upon price. If the value of the land exceeds the value of the houses, the
respondents may choose not to buy the land but must pay reasonable rent. If there is
disagreement, the trial court will determine the rental rate and other terms of the lease.
Alternatively, the respondents may remove or demolish the encroaching portions of their
houses at their own expense.
Reference:
https://jurisprudence.ph/jurisprudence/digest/ignao-v-intermediate-appellate-court?
q=G.R.+No.+72876#_
Title: I Ballatan vs. Court of Appeals

Case: G.R. No. 125683
Ponente: PUNO, J
Decision Date: Mar 2, 1999
Legal Principle/ Doctrine: The rights must be determined in accordance with Article
448 of the Civil Code, which allows the owner of the land to either appropriate the
improvements made by the encroacher or oblige the encroacher to buy the land.
Facts:
The case of Ballatan v. Court of Appeals involves a dispute over encroachment on
residential land. The petitioners, Eden Ballatan and spouses Betty Martinez and Chong
Chy Ling, filed a complaint against respondents Gonzalo Go, Winston Go, Li Ching Yao,
Araneta Institute of Agriculture (AIA), and Jose N. Quedding. The complaint sought the
recovery of possession of a portion of the petitioners' land that was encroached upon by
the respondents. The trial court ruled in favor of the petitioners, ordering the
respondents to vacate the encroached portion, demolish their improvements, and pay
damages and attorney's fees. The court also dismissed the third-party complaint filed by
the respondents against AIA, Quedding, and Yao.
Issue:
The main issue raised in the case is whether the respondents should be held liable for
encroaching on the petitioners' land and if they should be ordered to vacate the
encroached portion, demolish their improvements, and pay damages and attorney's
fees.
Ruling:
The Supreme Court held that the Court of Appeals correctly dismissed the third-party
complaint against AIA. The claim that the discrepancy in the lot areas was due to AIA's
fault was not proven. The Court also ruled that all the parties are presumed to have
acted in good faith. Therefore, their rights must be determined in accordance with Article
448 of the Civil Code. The Court modified the decision of the Court of Appeals by
ordering the parties to exercise their rights as owners and possessors of the land in
accordance with Article 448. The Court also affirmed the dismissal of the third-party
complaint against AIA and the award of attorney's fees to the respondents.
Ratio:
The Court based its decision on Article 448 of the Civil Code, which provides that the
owner of the land on which anything has been built, sown, or planted in good faith has
the right to appropriate the improvement after payment of the necessary and useful
expenses. The owner may also oblige the builder to purchase the land or pay rent. If the
parties cannot agree on the conditions of the lease, the court will fix the terms. In this
case, the Court held that the petitioners, as owners of the land, may choose to purchase
the improvement made by the respondents or sell the encroached portion of the land to
them. If buying the improvement is impractical, the respondents may be required to
vacate the land and pay rent. The price or rent must be fixed at the prevailing market
value at the time of payment. The Court also affirmed the award of attorney's fees to the
respondents and held that the additional filing fee on the damages constitutes a lien on
the award.
Reference:
https://jurisprudence.ph/jurisprudence/digest/ballatan-v-court-of-appeals?q=G.R.+No.
+125683#_
Title: Spouses Narvaez vs. Spouses Alciso
Case: G.R. No. 165907
Ponente: CARPIO, J
Legal Principle/ Doctrine: Article 448 of the Civil Code, which deals with the rights of
builders in good faith, only applies to land owners.
Facts:
This case involves a dispute over a property sale between the spouses Dominador R.
Narvaez and Lilia W. Narvaez (petitioners) and the spouses Rose Ogas Alciso and
Antonio Alciso (respondents). The property in question is a 1,329-square meter parcel
of land in Pico, La Trinidad, Benguet. The property was initially owned by Larry Ogas
and was later sold to Rose Alciso. Alciso then entered into a series of sale transactions
with different buyers, eventually selling the property to the petitioners. The petitioners
built a commercial building on the property.
Issue:
The main issue raised in the petition to the Supreme Court is whether Alciso effectively
communicated her acceptance of the favor contained in the stipulation pour autrui.
Ruling:
The Supreme Court ruled that all the requisites of a stipulation pour autrui were present
in this case, including the communication of acceptance by Alciso. The Court held that
the factual finding of the RTC, affirmed by the Court of Appeals, that Alciso
communicated her acceptance was binding. The Court also held that Article 448 of the
Civil Code, which pertains to the rights of builders in good faith, was not applicable in
this case because the petitioners were the owners of the land and not builders on
another person's land.
Ratio:
The Court found that the 1981 Deed of Sale of Realty contained a stipulation pour autrui
in favor of Alciso, allowing her to repurchase the property. The Court held that Alciso
effectively communicated her acceptance of this favor. The Court emphasized that the
factual finding of the RTC, affirmed by the Court of Appeals, that Alciso communicated
her acceptance was binding and could not be overturned.
The Court also clarified that Article 448 of the Civil Code, which pertains to the rights of
builders in good faith, was not applicable in this case. The petitioners were the owners
of the land and not builders on another person's land. Therefore, the rights and
protections afforded to builders in good faith under Article 448 did not apply to the
petitioners.
Based on these findings, the Supreme Court affirmed the decision of the Court of
Appeals. However, the Court modified the decision by stating that Alciso may exercise
her right of redemption by paying the petitioners the price of the sale, expenses of the
contract, legitimate payments made by reason of the sale, and necessary and useful
expenses made on the property. The Court directed the RTC to determine the amounts
of these expenses and gave Alciso 30 days to pay the amounts to the petitioners.
Reference:
https://jurisprudence.ph/jurisprudence/digest/spouses-narvaez-v-spouses-alciso?
q=G.R.+No.+165907%2C+July+27%2C+2009#_
Title: Spouses Macasaet vs. Spouses Macasaet
Case: G.R. No. 154391-92
Ponente: PANGANIBAN, J
Legal Principle/ Doctrine: Article 448 of the Civil Code should apply to the case
regarding the improvements made by the children. This provision grants the owner of
the land the right to appropriate the improvements after payment of indemnity.
Facts:
The case involves a dispute between parents and children over the possession of two
lots. The children were initially invited by the parents to occupy the lots. However, due to
an unresolved conflict, the parents asked the children to vacate the premises. The
children claimed that they have the right to remain on the property and sought
reimbursement for the improvements they made on the lots.
Issue:
The main issue in this case is whether the children have the right to remain on the
property and be indemnified for the improvements they made on the lots.
Ruling:
The court ruled that while the children lost their right to remain on the property, they
have the right to be indemnified for the improvements they made on the lots. The court
applied Article 448 of the Civil Code, which allows the owner of the land to appropriate
the improvements made by another person, but only after payment of indemnity. The
court affirmed the decision of the lower courts, ordering the parents to reimburse the
children for half the value of the improvements. The court also remanded the case to
determine the specific amount of indemnity and the option to be taken by the parents.
Ratio:
The court based its ruling on Article 448 of the Civil Code, which states that the owner of
the land on which improvements have been made in good faith shall have the right to
appropriate such improvements after payment of indemnity. In this case, the children
made improvements on the lots in good faith, believing that they had the right to occupy
the property. However, due to the unresolved conflict, the parents asked them to vacate
the premises. As a result, the children lost their right to remain on the property.
Nevertheless, the court recognized their right to be indemnified for the improvements
they made.
The court rejected the children's claims of inheritance and dation in payment, as there
was insufficient evidence to support these claims. The court also addressed other
issues raised by the parties, including the appearance at the preliminary conference and
the accountability of the judge and lawyers involved in the case. The court affirmed the
decision of the lower courts and modified it to delete the reimbursement for
improvements, remanding the case for further proceedings to determine the proper
application of Articles 448 and 546 of the Civil Code.
In summary, the court ruled that the children lost their right to remain on the property but
have the right to be indemnified for the improvements they made. The court applied
Article 448 of the Civil Code and ordered the parents to reimburse the children for half
the value of the improvements. The court remanded the case to determine the specific
amount of indemnity and the option to be taken by the parents. The court rejected the
children's claims of inheritance and dation in payment due to lack of evidence. The court
also addressed other issues raised by the parties and affirmed the decision of the lower
courts, modifying it to delete the reimbursement for improvements and remanding the
case for further proceedings.
Reference:
https://jurisprudence.ph/jurisprudence/digest/spouses-macasaet-v-spouses-macasaet?
q=G.R.+Nos.+154391-92%2C+September+30%2C+2004#_
Title: Pacific Farms, Inc. vs. Esguerra
Ponente: CASTRO, J
Decision Date: Nov 29, 1969
Legal Principle/ Doctrine: The court applied the rules of accession and concluded that
the buildings should be considered the principal and the lumber and construction
materials as the accessory; Compensation should be borne by the person who has
been benefited by the accession.
Facts:
The case of Pacific Farms, Inc. v. Esguerra involves a dispute over ownership and
compensation for unpaid materials used in the construction of buildings. The plaintiff,
Pacific Farms, Inc., claims ownership of six buildings that were constructed using
lumber and construction materials provided by the defendant, Carried Lumber
Company. The defendant argues that it is entitled to reimbursement for the unpaid
balance of the materials.
The defendant sold and delivered lumber and construction materials to the Insular
Farms, Inc., the predecessor-in-interest of the plaintiff, from October 1956 to March
1957. These materials were used by the Insular Farms, Inc. to construct six buildings.
However, the Insular Farms, Inc. failed to fully pay for the materials, resulting in an
outstanding balance of P4,710.18. The defendant then filed a civil case to recover the
unpaid balance, and the court ruled in favor of the defendant. As a result, the defendant
levied upon the six buildings and sold them at a public auction to satisfy the money
judgment.
Issue:
The main issue in the case is whether the defendant is entitled to reimbursement for the
unpaid materials and whether the sale at public auction was valid.
Ruling:
The court ruled in favor of the defendant, stating that the plaintiff is obligated to pay for
the value of the materials used in the construction of the buildings. The court applied the
principle of accession, which considers the buildings as the principal and the materials
as the accessory. As the owner of the buildings, the plaintiff is responsible for paying for
the materials. On the other hand, the defendant has the right to recover the value of the
unpaid materials.
The court also held that compensation should be borne by the person who has
benefited from the accession, which in this case is the plaintiff. The court found that the
plaintiff was not a buyer in good faith and for value, as it had knowledge of the unpaid
balance of the materials at the time of the sale.
As a result, the court declared the sale at public auction valid and effective. However,
considering the equities of the case, the court granted the plaintiff the option to redeem
the buildings by paying the unpaid balance within 30 days.
Ratio:
The court's decision was based on the principle of accession, which recognizes that the
buildings are the principal and the materials used in their construction are the
accessory. As the owner of the buildings, the plaintiff is obligated to pay for the
materials. The defendant, as the provider of the materials, has the right to recover the
value of the unpaid materials.
Furthermore, the court applied the principle of compensation, which states that the
person who has benefited from the accession should bear the obligation to compensate.
In this case, the plaintiff benefited from the construction of the buildings using the
defendant's materials. Therefore, the plaintiff should bear the responsibility to pay for
the materials.
The court also considered the plaintiff's knowledge of the unpaid balance of the
materials at the time of the sale. This knowledge negated the plaintiff's claim of being a
buyer in good faith and for value. As a result, the court validated the sale at public
auction.
However, in consideration of the equities of the case, the court granted the plaintiff the
option to redeem the buildings by paying the unpaid balance within 30 days. This
allowed the plaintiff to retain ownership of the buildings while fulfilling its obligation to
compensate the defendant for the unpaid materials.
In summary, the court ruled in favor of the defendant, granting them the right to
reimbursement for the unpaid materials and validating the sale at public auction. The
plaintiff was given the opportunity to redeem the buildings by paying the unpaid
balance.
Reference:
https://jurisprudence.ph/jurisprudence/digest/pacific-farms-inc-v-esguerra-30275?
q=G.R.+No.+L-21783#_
Title: Geminiano vs. Court of Appeals

Case: G.R. No. 120303
Ponente: DAVIDE, JR., J
Legal Principle/ Doctrine: Article 448, which allows full reimbursement and retention of
the premises, applies only to a possessor in good faith, not to a lessee.
Facts:
The case of Geminiano v. Court of Appeals involves a dispute over a lease contract and
the reimbursement for improvements made on the leased property. The petitioners,
Federico Geminiano and his family, filed a complaint for unlawful detainer and damages
against the private respondents, Dominador and Mary Nicolas, after the expiration of
the lease contract. The lower court ruled in favor of the petitioners, ordering the private
respondents to vacate the premises and pay reasonable compensation for their stay.
Issue:
The main issue in this case is whether the private respondents are builders in good faith
or mere lessees.
Ruling:
The Court held that the private respondents cannot be considered builders in good faith
because they were aware that their occupation of the premises was only temporary, as
they were mere lessees under a rental contract. The Court cited Article 448 of the Civil
Code, which allows full reimbursement of useful improvements and retention of the
premises until reimbursement is made, but only applies to possessors in good faith.
The Court also ruled that the private respondents' right to indemnity under Article 1678
of the Civil Code arises only if the lessor opts to appropriate the improvements. Since
the petitioners refused to exercise that option, the private respondents cannot compel
them to reimburse the value of the house and improvements. The private respondents'
only right is to remove the improvements without causing any more damage to the
property than necessary.
Ratio:
The Court based its decision on the provisions of the Civil Code. It cited Article 448,
which states that possessors in good faith are entitled to full reimbursement of useful
improvements and retention of the premises until reimbursement is made. However, the
Court found that the private respondents were not builders in good faith because they
were aware that their occupation of the premises was temporary as mere lessees.
Therefore, they cannot avail themselves of the rights granted under Article 448.
The Court also referred to Article 1678, which provides for the right to indemnity for
improvements made by the lessee. However, the Court clarified that this right only
arises if the lessor opts to appropriate the improvements. In this case, the petitioners did
not exercise that option, so the private respondents cannot compel them to reimburse
the value of the house and improvements. The private respondents' only right is to
remove the improvements without causing any more damage to the property than
necessary.
Based on these legal provisions, the Court granted the petition, reversed the decision of
the Court of Appeals, and reinstated the decision of the Municipal Trial Court in Cities,
ordering the private respondents to vacate the premises and pay reasonable
compensation for their stay.
Reference:
https://jurisprudence.ph/jurisprudence/digest/geminiano-v-court-of-appeals?q=G.R.+No.
+120303#_
Title: Pen Development Corp. vs. Martinez Leyba, Inc.
Case: G.R. No. 211845
Ponente: DEL CASTILLO, J
Legal Principle/ Doctrine: The phrase "innocent purchaser" should only apply to cases
where unregistered land has been wrongfully included in a certificate under the Torrens
system.
Facts:
The case involves a dispute between Martinez Leyba, Inc. (MLI) and Pen Development
Corporation and Las Brisas Resorts Corporation (Las Brisas) over the encroachment of
a fence on MLI's land. MLI is the registered owner of three parcels of land in Antipolo,
Rizal, while Las Brisas is the registered owner of a neighboring parcel of land. MLI
noticed that Las Brisas' fence encroached on its land and sent several letters informing
Las Brisas of the encroachment. Despite the notices, Las Brisas continued to develop
its property. MLI conducted a verification survey which confirmed the encroachment,
leading MLI to file a complaint for quieting of title, cancellation of title, and recovery of
ownership against Las Brisas.
Issue:
The main issue in this case is whether Las Brisas is a builder in bad faith and liable for
the consequences of its acts.
Ruling:
The Supreme Court upheld the Court of Appeals' decision, ruling that Las Brisas is a
builder in bad faith and ordering the cancellation of portions of its title. The Court also
ordered Las Brisas to vacate the encroached portions and pay nominal damages to
MLI.
Ratio:
The Court held that MLI's verification survey, which was a public document, was
admissible in evidence and remained unrefuted by Las Brisas. This survey confirmed
the encroachment and supported MLI's claim. The Court also ruled that Las Brisas,
despite being an innocent purchaser for value, was not a possessor and builder in good
faith. This is because Las Brisas continued to construct on the disputed area despite
being informed of the encroachment. The Court emphasized that the principle of laches
does not apply to registered land covered by the Torrens system. Therefore, Las Brisas
cannot claim good faith based on the doctrine of indefeasibility of its title.
In dissent, one Justice argued that Las Brisas should be considered a possessor in
good faith because it built within its titled property and relied on the validity and
indefeasibility of its title. The Justice also questioned the application of the constructive
notice doctrine in determining good faith, arguing that the fact that Las Brisas built within
its titled property should be factored in.
In conclusion, the Supreme Court upheld the Court of Appeals' ruling that Las Brisas is
a builder in bad faith. The Court relied on MLI's verification survey as evidence of the
encroachment and rejected Las Brisas' claim of good faith. The dissenting opinion
argued for a more factual approach and suggested that the rights and obligations of the
parties should be determined under Article 448 of the Civil Code.
Reference:
https://jurisprudence.ph/jurisprudence/digest/pen-development-corp-v-martinez-leyba-
inc?q=G.R.+No.+211845%2C+august+9%2C+2017#_
Title: Viajar vs. Court of Appeals
Ponente: MEDIALDEA, J
Decision Date: Dec 12, 1988
Legal Principle/ Doctrine: Accretion belongs to the owners of the lands adjoining the
river, regardless of whether the land is registered under the Torrens System.
Facts:
The case of Viajar v. Court of Appeals involves a dispute over the ownership of land
formed through accretion from a river. The plaintiffs, Angelica Viajar and Celso Viajar,
purchased a parcel of land from Rosendo Te and later discovered that the land was in
the possession of the defendants, the Ladrido family. The plaintiffs filed a civil action for
recovery of possession and damages against the Ladrido family. The trial court ruled in
favor of the defendants, declaring them as the owners of the disputed land. The
plaintiffs appealed to the Court of Appeals, but their appeal was denied. They then filed
a petition for review on certiorari with the Supreme Court.
Issue:
The main issue raised in the case is whether the change in the course of the Suague
River, which resulted in the formation of the disputed land, was sudden or gradual. The
plaintiffs argue that the change was sudden, while the defendants contend that it was
gradual. The trial court and the Court of Appeals both found that the change was
gradual based on the evidence presented.
Ruling:
The ruling of the Court of Appeals, which affirmed the decision of the trial court, is that
the defendants are the rightful owners of the disputed land. The court applied Article
457 of the New Civil Code, which states that the owners of lands adjoining the banks of
rivers are entitled to the accretion gradually received from the effects of the current of
the waters. The court held that the change in the course of the river was gradual and
caused by accretion, and therefore, the accretion belongs to the owners of the adjoining
lands.
Ratio:
The court also rejected the plaintiffs' argument that the accretion should not extend to
registered land under the Torrens System. The court cited previous rulings that
registration under the Torrens System does not protect the riparian owner against the
diminution of the area of his registered land through gradual changes in the course of
an adjoining stream. The court emphasized that accretions of this nature are natural
incidents to land bordering on running streams and are not affected by the registration
laws.
Based on these arguments and legal principles, the Supreme Court dismissed the
petition for lack of merit. The court upheld the ruling of the Court of Appeals, affirming
the defendants as the owners of the disputed land. The court also stated that no
damages are recoverable from the defendants, as they are the rightful owners of the
premises in question.
Reference:
https://jurisprudence.ph/jurisprudence/digest/viajar-v-court-of-appeals?q=G.R.+No.
+77294#_
Title: Daclison vs. Baytion
Case: G.R. No. 219811
Ponente: MENDOZA, J
Decision Date: Apr 6, 2016
Legal Principle/ Doctrine: The Court cited Article 457, which states that the owners of
lands adjoining rivers are entitled to the accretion gradually received from the current of
the waters; The Court found that the disputed portion did not meet the requirements for
accretion, as it was not a gradual and imperceptible deposit caused by the natural
current of a river or creek; The Court also referred to Article 445, which states that
improvements or repairs made on another person's land belong to the owner of the
land; The Court interpreted this provision to mean that the improvements must be made
within or on the property itself, and not outside of it.
Facts:
The case of Daclison v. Baytion involves a dispute over the ownership and possession
of a parcel of land. The respondent, Baytion, filed a complaint against the defendant,
Daclison, for forcible entry and damages. Baytion claimed that he was a co-owner of the
land and that Daclison had taken possession of a portion of it without his consent. On
the other hand, Daclison argued that he had a valid lease agreement with Baytion's
predecessor and had been occupying the disputed portion with permission. The
Metropolitan Trial Court initially dismissed the case for failure to include all co-owners as
plaintiffs. However, the Regional Trial Court assumed jurisdiction and ruled in favor of
Baytion. The Court of Appeals affirmed the RTC's decision, prompting Daclison to file a
petition for review.
Issue:
The main issues raised in the case were whether the Regional Trial Court had
jurisdiction over the case and who had a better right to possess the disputed portion of
land.
Ruling:
The Supreme Court ruled in favor of Daclison, dismissing the complaint for possession
filed by Baytion.
Ratio:
The Supreme Court held that the Regional Trial Court had jurisdiction over the case. It
found that the disputed portion of land was not an accretion or improvement on
Baytion's property. Additionally, the Court determined that Daclison had a valid lease
agreement with Baytion's predecessor, which allowed him to occupy the disputed
portion with permission. Therefore, Baytion did not have a valid claim of ownership and
could not eject Daclison from the land.
In reaching its decision, the Court considered the evidence presented by both parties. It
found that Daclison had presented a lease agreement that was duly executed and
notarized. This agreement established his right to occupy the disputed portion of land.
On the other hand, Baytion failed to provide any evidence to support his claim of
ownership. He merely asserted that he was a co-owner of the land without presenting
any proof to substantiate this claim.
Furthermore, the Court emphasized that possession is an essential element in an action

for forcible entry. In this case, Daclison had been in possession of the disputed portion
of land with permission. Baytion, on the other hand, failed to establish his right to
possess the land. Therefore, Daclison had a better right to possess the land and
Baytion's complaint for possession was dismissed.
In conclusion, the Supreme Court ruled in favor of Daclison, stating that Baytion did not
have a valid claim of ownership and therefore did not have the right to eject Daclison
from the disputed portion of land. The Court held that the Regional Trial Court had
jurisdiction over the case and ultimately dismissed Baytion's complaint for possession.
Reference:
https://jurisprudence.ph/jurisprudence/digest/daclison-v-baytion?q=G.R.+No.
+219811%2C+April+6%2C+2016#_
Title: Chua v. Lo
Case: G.R. No. 196743
Ponente: REYES, J. JR., J.
Decision Date: August 14, 2019
Legal Principle/ Doctrine: In an action for quieting of title, the complainant is seeking
for an adjudication that a claim of title or interest in property adverse to the claimant is
invalid, to free him from the danger of hostile claim, and to remove a cloud upon or quiet
title to land where stale or unenforceable claims or demands exist. For an action to quiet
title to prosper, two indispensable requisites must concur, namely: (1) the plaintiff or
complainant has a legal or an equitable title to or interest in the real property subject of
the action; and (2) the deed, claim, encumbrance, or proceeding claimed to be casting
cloud on his title must be shown to be in fact invalid or inoperative despite its prima
facie appearance of validity or legal efficacy.
Facts:
The case of Spouses Chua v. Spouses Lo involves a dispute over ownership and
possession of a parcel of land in Sta. Cruz, Laguna, Philippines. The petitioners,
Spouses Lolito Chua and Myrna Palomaria, and Spouses Sergio Chua and Elena Chua,
filed a complaint for Quieting of Title, Annulment of Sale, Recovery of Possession and
Damages against the respondents, Spouses Agustin Lo and Josefina N. Becina, Victor
Lo, and Agustin Lo Realty Corporation. The petitioners sought to quiet title over a parcel
of land covered by Transfer Certificate of Title (TCT) No. T-114915, annul a Deed of
Sale executed by Victor Lo in favor of Agustin Lo Realty Corporation, and recover
possession of a 600 sq m portion of the land.
The facts of the case are as follows: The petitioners, Spouses Chua, were the owners of
a parcel of coconut land (Lot 505) in Sta. Cruz, Laguna. They sold a portion of Lot 505
to Delia N. Becina and Josefina N. Becina through two separate sales in 1976 and
1977. Lot 505 was later subdivided into two lots, Lot 505-A and Lot 505-B. Lot 505-B
was further subdivided into three lots, one of which is Lot 505-B-3. A confrontation was
held among the parties to settle a dispute regarding the area of the lots sold to Delia
and Josefina. They eventually agreed that Lot 505-B-2 would be conveyed to Josefina,
while Lot 505-B-3 would remain in the name of Lolito. Lot 505-B-3 was further
subdivided into Lot 505-B-3-A and Lot 505-B-3-B. A Deed of Sale was executed in 1984,
wherein Lolito sold Lot 505-B-2 to Josefina, and Lot 505-B-3-A was sold to Sergio,
Lolito's brother. However, Josefina and her spouse Agustin forcibly occupied the entire
Lot 505-B-3, including Lot 505-B-3-A. Victor Lo, the husband of Delia who passed away,
sold the entire Lot 505-B-3 to Agustin Lo Realty Corporation. The petitioners demanded
the respondents to vacate Lot 505-B-3-A and remove the construction on it, but the
respondents refused.
Issue:
The main issue in the case is whether or not the petitioners are entitled to recover Lot
505-B-3-A, which allegedly represents the excess area sold to Delia and Josefina.
Ruling:
The court ruled in favor of the petitioners. It held that the sale of Lot 505-B-3 by Victor
Lo to Agustin Lo Realty Corporation is null and void insofar as the 600 sq m area is
concerned. The court found that the total area delivered to Josefina and Delia was in
excess of 600 sq m, as the petitioners had conveyed a total of 5,612 sq m, which is 600
sq m more than the original 5,012 sq m agreed upon in the sale transactions. The court
also ruled that the petitioners have a legal title to Lot 505-B-3-A, as it is covered by a
certificate of title in the name of Sergio. The court ordered Agustin Lo Realty
Corporation to surrender possession of Lot 505-B-3-A to the estate of Sergio Chua.
Additionally, the court ordered the petitioners to deliver the 500 sq m subject of the 1975
sale transaction between Myrna Chua and Josefina Lo.
Ratio:
The court based its ruling on the evidence presented, including the deeds of sale, the
subdivision of the lots, and the agreement among the parties. It found that the 1976 and
1977 sale transactions were contracts to sell, and the subsequent 1984 deed of sale
was an off-shoot of these contracts. The court also considered the admissions and
actions of the parties, such as the execution of the deeds of extra-judicial partition and
sale by Delia's heirs, as well as the issuance of certificates of title. The court concluded
that the respondents have no right to the 600 sq m portion of the land and that the
petitioners are entitled to quiet title and recover possession of Lot 505-B-3-A.
The spouses Lolito and Myrna
(spouses Chua) were the owners of
a parcel of coconut
land (Lot 505) located in Sta. Cruz,
Laguna, with an area of 21,644 sq
m and covered by
Original Certificate of Title No. P-
3264. On January 15, 1976,
Myrna, with the consent of Lolito,
sold to sisters Delia N. Becina
(Delia) and Josefina N. Becina
(Josefina),[4] a portion of Lot No.
505 with an area of 4,612 sq m. On
August 5, 1977, Lolito, with the
consent of Myrna, sold to
Delia and Josefina[5] an additional
400 sq m of Lot No. 505. All in all,
Josefina and Delia
acquired from the spouses Chua a
total area of 5,012 sq m as a result
of these two sales.
The case arose from a Complaint
for Quieting of Title, Annulment
of Sale, Recovery of
Possession and Damages, with
Preliminary Injunction filed by
petitioners spouses Lolito Chua
(Lolito) and Myrna Palomaria
(Myrna) and spouses Sergio Chua
(Sergio) and Elena Chua
(Elena) seeking to:
a parcel of coconut
m and covered by
3264. On January 15, 1976,
Josefina and Delia
of these two sales.
(Elena) seeking to:
a parcel of coconut
m and covered by
3264. On January 15, 1976,
Josefina and Delia
of these two sales.
(Elena) seeking to:
Facts:
The case of Spouses Chua v. Spouses Lo involves a dispute over ownership and
possession of a parcel of land in Sta. Cruz, Laguna, Philippines. The petitioners,
Spouses Lolito Chua and Myrna Palomaria, and Spouses Sergio Chua and Elena Chua,
filed a complaint for Quieting of Title, Annulment of Sale, Recovery of Possession and
Damages against the respondents, Spouses Agustin Lo and Josefina N. Becina, Victor
Lo, and Agustin Lo Realty Corporation. The petitioners sought to quiet title over a parcel
of land covered by Transfer Certificate of Title (TCT) No. T-114915, annul a Deed of
Sale executed by Victor Lo in favor of Agustin Lo Realty Corporation, and recover
possession of a 600 sq m portion of the land.
The facts of the case are as follows: The petitioners, Spouses Chua, were the owners of
a parcel of coconut land (Lot 505) in Sta. Cruz, Laguna. They sold a portion of Lot 505
to Delia N. Becina and Josefina N. Becina through two separate sales in 1976 and
1977. Lot 505 was later subdivided into two lots, Lot 505-A and Lot 505-B. Lot 505-B
was further subdivided into three lots, one of which is Lot 505-B-3. A confrontation was
held among the parties to settle a dispute regarding the area of the lots sold to Delia
and Josefina. They eventually agreed that Lot 505-B-2 would be conveyed to Josefina,
while Lot 505-B-3 would remain in the name of Lolito. Lot 505-B-3 was further
subdivided into Lot 505-B-3-A and Lot 505-B-3-B. A Deed of Sale was executed in 1984,
wherein Lolito sold Lot 505-B-2 to Josefina, and Lot 505-B-3-A was sold to Sergio,
Lolito's brother. However, Josefina and her spouse Agustin forcibly occupied the entire
Lot 505-B-3, including Lot 505-B-3-A. Victor Lo, the husband of Delia who passed away,
sold the entire Lot 505-B-3 to Agustin Lo Realty Corporation. The petitioners demanded
the respondents to vacate Lot 505-B-3-A and remove the construction on it, but the
respondents refused.
Issue:
The main issue in the case is whether or not the petitioners are entitled to recover Lot
505-B-3-A, which allegedly represents the excess area sold to Delia and Josefina.
Ruling:
The court ruled in favor of the petitioners. It held that the sale of Lot 505-B-3 by Victor
Lo to Agustin Lo Realty Corporation is null and void insofar as the 600 sq m area is
concerned. The court found that the total area delivered to Josefina and Delia was in
excess of 600 sq m, as the petitioners had conveyed a total of 5,612 sq m, which is 600
sq m more than the original 5,012 sq m agreed upon in the sale transactions. The court
also ruled that the petitioners have a legal title to Lot 505-B-3-A, as it is covered by a
certificate of title in the name of Sergio. The court ordered Agustin Lo Realty
Corporation to surrender possession of Lot 505-B-3-A to the estate of Sergio Chua.
Additionally, the court ordered the petitioners to deliver the 500 sq m subject of the 1975
sale transaction between Myrna Chua and Josefina Lo.
Ratio:
The court based its ruling on the evidence presented, including the deeds of sale, the
subdivision of the lots, and the agreement among the parties. It found that the 1976 and
1977 sale transactions were contracts to sell, and the subsequent 1984 deed of sale
was an off-shoot of these contracts. The court also considered the admissions and
actions of the parties, such as the execution of the deeds of extra-judicial partition and
sale by Delia's heirs, as well as the issuance of certificates of title. The court concluded
that the respondents have no right to the 600 sq m portion of the land and that the
petitioners are entitled to quiet title and recover possession of Lot 505-B-3-A.
Reference:
https://jurisprudence.ph/jurisprudence/digest/spouses-chua-v-spouses-lo?q=G.R.
+No+196743%2C+August+14%2C+2019#_
Title: Green Acres Holdings, Inc. vs. Cabral

Case: G.R. No. 175542 & 183205
Ponente: VILLARAMA, JR., J
Decision Date: Jun 5, 2013
Legal Principle/ Doctrine: A writ of execution can only be issued against a party to the
case and not against one who did not have his day in court; The irrevocability and
indefeasibility of a Torrens title protects an innocent purchaser for value.
Facts:
The case of Green Acres Holdings, Inc. v. Cabral involves two consolidated petitions for
review on certiorari. Green Acres Holdings, Inc. (Green Acres) appeals the dismissal of
its appeal from the Regional Trial Court (RTC) by the Court of Appeals (CA). Victoria
Cabral seeks to set aside the CA's decision and resolution in her petition for certiorari.
Victoria Cabral was the original owner of a parcel of land in Bulacan. The land was
placed under the coverage of Presidential Decree (P.D.) No. 27, and Emancipation
Patents were issued to the spouses Enrique Moraga and Victoria Soriano (Spouses
Moraga). Cabral filed a complaint seeking the cancellation of the Emancipation Patents,
but the complaint was dismissed. Cabral appealed to the Department of Agrarian
Reform Adjudication Board (DARAB).
While the appeal was pending, the Spouses Moraga subdivided the land and sold it to
Filcon Ready Mixed Inc. (Filcon). Green Acres later purchased the properties from
Filcon. The DARAB eventually rendered a decision ordering the cancellation of the titles
issued to the Spouses Moraga and Filcon.
Green Acres, unaware of the DARAB decision, constructed a warehouse building

complex on the properties. When it learned about the DARAB decision, Green Acres
sent a letter to Filcon reminding them of their warranties under the deed of sale. Filcon
replied that it was also an innocent purchaser for value and was coordinating with the
Spouses Moraga to protect Green Acres' interest.
Green Acres then filed a complaint for Quieting of Title, claiming to be a purchaser in
good faith and for value. Cabral denied the allegations and argued that the trial court
had no jurisdiction over the subject property. The trial court granted Cabral's demurrer to
evidence and dismissed the case. Green Acres appealed to the CA, but the appeal was
dismissed.
Meanwhile, Cabral filed a motion for execution of the DARAB decision. The PARAD
denied the motion, ruling that the decision did not direct the cancellation of Green Acres'
titles. Cabral filed a petition for certiorari with the CA, which also denied her petition.
Issue:
The main issues raised in the case are as follows:
Whether the DARAB decision can be enforced against Green Acres

Whether Green Acres is an innocent purchaser for value
Ruling:
The Supreme Court ruled in favor of Green Acres. It held that the DARAB decision
cannot be enforced against Green Acres because it was not a party to the case. The
Court also emphasized the importance of the Torrens system in protecting innocent
purchasers for value. The Court further held that the DARAB decision constitutes a
cloud on Green Acres' title, and therefore, Green Acres is entitled to have the cloud
removed through an action for quieting of title. The Court reversed the CA's decision in
G.R. No. 175542 and affirmed the CA's decision in G.R. No. 183205.
Ratio:
The Court held that the DARAB decision cannot be enforced against Green Acres
because it was not a party to the case. Only parties to a case are bound by the decision
rendered therein. Since Green Acres was not involved in the proceedings before the
DARAB, it cannot be compelled to comply with the decision.
The Court also emphasized the importance of the Torrens system in protecting innocent
purchasers for value. The Torrens system is a method of registering land titles to
provide security and stability in land ownership. Under this system, a person who
acquires a property covered by a Torrens title in good faith and for value is protected
and his or her title cannot be defeated by any claim or encumbrance not noted on the
title.
In this case, Green Acres purchased the properties from Filcon, who in turn acquired
them from the Spouses Moraga. Green Acres had no knowledge of the DARAB decision
when it purchased the properties. Therefore, Green Acres is considered an innocent
purchaser for value and is entitled to the protection of the Torrens system.
The Court further held that the DARAB decision constitutes a cloud on Green Acres'
title. A cloud on title refers to any instrument, claim, or encumbrance that may cast
doubt on the validity or effectiveness of a property owner's title. In this case, the DARAB
decision ordering the cancellation of the titles issued to the Spouses Moraga and Filcon
creates a cloud on Green Acres' title. Therefore, Green Acres is entitled to have the
cloud removed through an action for quieting of title.
Based on these reasons, the Court reversed the CA's decision in G.R. No. 175542 and
affirmed the CA's decision in G.R. No. 183205. Green Acres is not bound by the DARAB
decision and is considered an innocent purchaser for value. It is entitled to have the
cloud on its title removed through an action for quieting of title.
Reference:
https://jurisprudence.ph/jurisprudence/digest/green-acres-holdings-inc-v-cabral?q=G.R.
+No.+175542+%26+183205%2C+June+5%2C+2013#_

CASE DIGESTS-idd (M1-3)

Uploaded by

Document Information

Copyright

Available Formats

Share this document

Share or Embed Document

Sharing Options

Did you find this document useful?

Is this content inappropriate?

Copyright:

Available Formats

CASE DIGESTS-idd (M1-3)

Uploaded by

Copyright:

Available Formats

Title: Federation of Coron, Busuanga, Palawan Farmer's Association, Inc. vs.

Secretary of the Department of Environment and Natural Resources

The petitioners, Federation of Coron, Busuanga, Palawan Farmer's Association, Inc.

Legal Principle/ Doctrine: Ports include seaports and airports.

The Court explained that MIAA is not a government-owned or controlled corporation

Whether the possessory information titles of the Medallas' predecessor-in-interest were

Legal Principle/ Doctrine: In land registration proceedings, being in rem, there is no

On February 1980, Antonia Victorino, respondent’s predecessor-in-interest, filed an

Title: I Ballatan vs. Court of Appeals

Title: Geminiano vs. Court of Appeals

Furthermore, the Court emphasized that possession is an essential element in an action

Title: Green Acres Holdings, Inc. vs. Cabral

Green Acres, unaware of the DARAB decision, constructed a warehouse building

Whether the DARAB decision can be enforced against Green Acres

You might also like