G.R. No. 159230 - B.E. San Diego, Inc. vs. Court of Appeals

B.E. San Diego, Inc. is the registered owner of a parcel of land located along Hernandez Street, Malabon, as evidenced by Transfer Certificate of Title (TCT) No. T-134756.
The title describes the property as Lot No. 3, Block No. 13, with an area of 228 square meters.
Although the TCT designates the property’s location in Barrio Tinajeros, evidence indicates that the actual subject property is situated in Barrio Catmon.

B.E. San Diego claimed that Jovita Matias had been occupying the subject property for more than a year without authority.
Owing to unheeded oral and written demands to vacate, B.E. San Diego filed a complaint for recovery of possession before the Regional Trial Court (RTC) of Malabon.
In her answer, Matias asserted that she and her family had been residing on the property since the 1950s, relying on a 1954 permit issued by the local government of Malabon.

TCT No. T-134756 covering Lot No. 3, Block No. 13;
An Approved Subdivision Plan identifying the same lot in Barrio Catmon;
A tax declaration which also referred to Lot No. 3, Block No. 13.
Testimonial evidence affirming that the property described in the title is the same as that occupied by Matias.

The local government permit granted in 1954;
A Miscellaneous Sales Application;
Evidence of substantial improvements made on the property;
Proof of annual realty tax payments since 1974;
Her qualification as a beneficiary under Presidential Decree (PD) Nos. 1517 and 2016.

The RTC ruled in favor of B.E. San Diego, finding that the property covered by the title (even though recorded as in Barrio Tinajeros) was indeed the same property occupied by Matias, taking judicial notice that Barrio Catmon was previously part of Barrio Tinajeros.
The RTC rejected Matias’ claims which were based on long possession and her PD benefits.
On appeal, the Court of Appeals (CA) reversed the RTC’s decision primarily due to the noted discrepancy in location, asserting that the difference should have been explained by an expert witness and recognizing Matias’ actual possession under Article 538 of the Civil Code, as well as her claim under the PD provisions.

Dissatisfied with the reversal by the CA, B.E. San Diego filed a petition for review on certiorari, contending that:

The discrepancy in location had been adequately addressed by the evidence;
Matias was estopped from now asserting that the property being occupied differed from the property described in the title, particularly after her prior invocation of res judicata in an earlier ejectment case.

Whether the property described in B.E. San Diego’s TCT (located in Barrio Tinajeros) is the same as the property occupied by Matias (located in Barrio Catmon).

Whether the discrepancy in the recorded barrio could be resolved by judicial notice and existing evidence without necessitating testimony from an expert witness.

Whether Matias acquired a superior right of possession, through long occupancy, tax payments, and as a beneficiary of PD Nos. 1517 and 2016, over B.E. San Diego’s title.

Whether Matias’ previous reliance on res judicata in an ejectment case implicitly recognized the identity of the subject matter, thereby barring her current objection regarding the property’s location.