G.R. No. 155830 - Abobon vs. Abobon

The dispute involves the rightful possession of a parcel of registered land in Poblacion, Labrador, Pangasinan, measuring approximately 4,668 square meters.
The parties are Numeriano P. Abobon (petitioner) and his first cousins, Felicitas Abata Abobon and Gelima Abata Abobon (respondents).
The respondents, who hold Transfer Certificate of Title (TCT) No. 201367, claim ownership and assert that they allowed Numeriano to use the land only as an act of benevolence.

Respondents initiated an action for recovery of possession and damages in the 2nd Municipal Circuit Trial Court (MCTC) of Labrador-Sual, Pangasinan.

They claimed that the land had long been within their family through successive transactions and inheritance.
They alleged that while they had permitted Numeriano free use of the property after the 1989 palay harvest, they later demanded its return as they needed the land for their own use.

In his defense, Numeriano admitted his relationship with the respondents and the existence of TCT No. 201367.

He contended that he was the lawful owner by right of succession, having inherited a 3,000 square meter portion of the property from his parents.
He asserted that this portion, which he was tilling and even claimed was donated by his grandfather via donation propter nuptias, was distinct from the parcel covered by the respondents’ title.

The MCTC’s decision (August 23, 2000) favored the respondents by establishing a historical chain of transactions:

The land was purchased in 1941 by Leodegario Abobon and Macaria Abata from Emilio Abobon and later sold, registered, repurchased, and ultimately inherited by the respondents.
The court found that the donation propter nuptias allegedly applicable to Numeriano’s parents was invalid due to its lack of written acceptance and subsequent cancellation by acts indicating a dissolution of its terms.

The Regional Trial Court (RTC) in Lingayen City affirmed the MCTC ruling on April 16, 2001, emphasizing that:

The land described in Numeriano’s evidence was factually different from the registered parcel.
The respondents had merely allowed Numeriano to use the land out of benevolence and not by any recognition of his title.

The Court of Appeals (CA) later affirmed the RTC decision on May 16, 2002, holding that:

The respondents’ TCT enjoyed the conclusive presumption of validity under the Torrens system.
Numeriano’s attempt to challenge the respondents’ title was a collateral attack and should have been pursued in a separate action for annulment of the TCT.

His continuous, public, and adverse possession of the 3,000 square meter parcel for more than 59 years.
His assertion that the land was inherited from his parents who received it via a donation propter nuptias from his grandfather.

The donated land and the parcel in question differed in area and boundaries.
Evidence supported the respondents’ series of transactions, registrations, and possession that affirmed their title.

Additional issues involved disputes over the propriety of awarding moral damages, exemplary damages, and attorney’s fees against Numeriano.

Whether Numeriano’s claim of being the lawful owner, based on his alleged inheritance and continuous possession of a 3,000 square meter portion, negates the respondents’ title.
Whether the respondents’ certificate of title, under the Torrens system and the doctrine of indefeasibility, gives them a preferential right to the possession of the land regardless of Numeriano’s allegations.
Whether the Court of Appeals erred in awarding possession to the respondents without a detailed explanation and despite evidence presented by Numeriano that he acquired ownership prior to the respondents’ succession.
Whether Numeriano should have brought a separate, direct action to annul the respondents’ TCT rather than raising the issue collaterally in his possessory action.
Whether the award of moral damages, exemplary damages, and attorney’s fees against Numeriano is justified given the lack of concrete evidence and proper factual findings to support such awards.