Case Digest (G.R. No. 199448)
Facts:
The case involves Rolando S. Abadilla, Jr. as the petitioner and spouses Bonifacio P. Obrero and Bernabela N. Obrero as the respondents. The events leading to the case began when the respondents filed a complaint for forcible entry against the petitioner on October 1, 2007, in the Municipal Trial Court in Cities (MTCC) of Laoag City. The respondents claimed to be the registered owners of a parcel of land, Lot No. 37565, Psd 01-065731, located in Barangay 37, Calayab, Laoag City, covered by Transfer Certificate of Title (TCT) No. T-38422, issued on July 3, 2007. They alleged that on September 22, 2007, the petitioner, with armed men, forcibly fenced the land, intimidated the respondents and their customers, and destroyed some improvements on the property. The respondents sought damages, including attorney's fees, and requested a preliminary mandatory injunction to maintain the status quo.
In response, the petitioner denied the allegations, asserting that he and his co-he...
Case Digest (G.R. No. 199448)
Facts:
Ownership Claims:
- The respondents, Spouses Bonifacio P. Obrero and Bernabela N. Obrero, claimed to be the registered owners of Lot No. 37565, covered by Transfer Certificate of Title (TCT) No. T-38422 issued on July 3, 2007. They alleged that they had been in possession of the land since 1991, using it for residential and business purposes.
- The petitioner, Rolando S. Abadilla, Jr., claimed that he and his co-heirs inherited the land from his father, Rolando Abadilla, Sr., who allegedly purchased it from the respondents in 1991 through a Deed of Absolute Sale.
Forcible Entry Complaint:
- On September 22, 2007, the petitioner, with armed men, forcibly fenced the land with barbed wire, destroyed improvements, and intimidated the respondents and their customers.
- The respondents filed a complaint for forcible entry before the Municipal Trial Court in Cities (MTCC) on October 1, 2007, seeking damages and a preliminary mandatory injunction.
Petitioner’s Defense:
- The petitioner denied the allegations, claiming that he and his co-heirs had fenced the land in 1996 as a safety measure since they resided in Metro Manila. He argued that the respondents had no right to the land as it had been sold to his father in 1991.
- He also questioned the validity of the respondents’ TCT, alleging that it was irregularly issued.
MTCC Ruling:
- The MTCC dismissed the complaint, ruling that the respondents had sold the land to Abadilla, Sr. in 1991, transferring ownership and possession to the petitioner and his co-heirs.
RTC and CA Rulings:
- The Regional Trial Court (RTC) reversed the MTCC, finding the respondents’ claims more credible and ruling that the 1991 Deed of Absolute Sale was invalid due to lack of consideration.
- The Court of Appeals (CA) affirmed the RTC’s decision, holding that the respondents, as registered owners, were entitled to possession.
Issue:
- (Unlock)
Ruling:
- (Unlock)
Ratio:
Ejectment Proceedings:
- Ejectment cases are summary proceedings intended to resolve issues of possession, not ownership. The courts may provisionally determine ownership only to decide who has a better right to possession.
Torrens Title:
- A Torrens certificate of title is evidence of indefeasible and incontrovertible ownership, which includes the right to possession. The respondents’ TCT must prevail over the petitioner’s unregistered Deed of Absolute Sale.
Collateral Attack on Title:
- The validity of a Torrens title cannot be collaterally attacked in ejectment proceedings. Any challenge to the title must be made in a direct proceeding for cancellation of title.
Preponderance of Evidence:
- The respondents provided overwhelming evidence of actual possession, including improvements on the land, tax declarations, and payment of realty taxes. The petitioner’s claims were based on unreliable affidavits and lacked sufficient proof of possession.
Forum Shopping:
- The Court found no evidence of forum shopping, as the related cases involved different properties and issues.
Conclusion:
The Supreme Court upheld the CA’s decision, ruling that the respondents, as registered owners, were entitled to possession of the land. The petitioner’s claims of ownership and possession were unsubstantiated, and the respondents’ Torrens title must prevail.