Case Digest (G.R. No. L-5833)
Facts:
The case involves Flaviana Acuna and Eusebia Diaz as plaintiffs and appellants against the Furukawa Plantation Company, the defendant and appellee. The events leading to this case took place in the Province of Davao, where the Furukawa Plantation Company is the registered owner of a large tract of land, evidenced by original certificate of title No. 2768, which was issued over 30 years prior to the case. Following World War II, this land was turned over to the National Abaca and Other Fibers Corporation (NAFCO) for administration and distribution among war veterans and deserving civilians, with each receiving an allocation of five hectares. Flaviana Acuna and her daughter Eusebia Diaz were among those allocated land but rejected their allocation, asserting their entitlement to the entire area they occupied, which amounted to approximately 31 hectares. Their claim was based on the fact that Flaviana's deceased husband, Roman Diaz, had been granted a provisional permit to o...
Case Digest (G.R. No. L-5833)
Facts:
Background of the Case
- The Furukawa Plantation Company, a Philippine corporation, is the registered owner of a large tract of land in Davao Province, evidenced by Transfer Certificate of Title No. 276.
- The land was originally registered over 30 years prior to the case, and its title had become indefeasible.
- After World War II, the land, along with other Japanese-owned properties, was administered by the National Abaca and Other Fibers Corporation (NAFCO) and distributed to war veterans and civilians, with each recipient allocated five hectares.
Plaintiffs' Claims
- Flaviana Acuna and Eusebia Diaz, plaintiffs, were allocated five hectares but rejected the offer, claiming entitlement to 31 hectares of land they occupied as homesteaders.
- They alleged that Roman Diaz (Flaviana's deceased husband and Eusebia's father) was granted a provisional permit in 1914 to occupy and cultivate 31.79 hectares of public land in sitio Calanitoi, Davao.
- Plaintiffs claimed continuous cultivation and improvement of the land, including planting coconut trees, fruit trees, and food crops, and building two residential houses.
- They accused the defendant of fraudulently including their land in its certificate of title, though the title contained a general annotation excluding improvements belonging to other persons.
- Plaintiffs sought:
- Declaration and annotation of their names as owners of the improvements in the defendant's title.
- Cession of the 31.79 hectares of land to them.
- Damages and an injunction against further dispossession and depredations by the defendant's agents.
Procedural History
- The defendant moved to dismiss the complaint, arguing:
- The complaint failed to state a cause of action.
- The action had prescribed.
- The court lacked jurisdiction over the subject matter.
- The Court of First Instance of Davao granted the motion to dismiss.
- Plaintiffs appealed to the Court of Appeals, which certified the case to the Supreme Court due to the nature of the issues involved.
Issue:
- (Unlock)
Ruling:
- (Unlock)
Ratio:
Amendments to Torrens Titles:
- Amendments to Torrens certificates of title must be pursued in the original land registration case, not through an action for declaratory relief. Proper notice to all affected parties is required.
Specific Performance and Land Ownership:
- Specific performance is only available to enforce contractual obligations. Plaintiffs could not compel the defendant to cede the land, as no contract existed between them.
- Under Article 448 of the Civil Code, the landowner has the exclusive right to choose between acquiring the improvements or selling the land to the improver.
Defective Pleadings:
- A complaint seeking damages and an injunction must clearly identify and delimit the property in question. Failure to do so renders the complaint defective.
Disposition
- The Supreme Court affirmed the dismissal of the first and second causes of action.
- The third cause of action was deemed dismissed unless plaintiffs amended their complaint to specify the land's boundaries within ten days of the decision becoming final.
- No costs were awarded.