Case Digest (G.R. No. 125683) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In Eden Ballatan and Spouses Betty Martinez and Chong Chy Ling v. Court of Appeals et al. (G.R. No. 125683, March 2, 1999), petitioners are registered owners of Lot No. 24 (414 sq. m.) in Araneta University Village, Malabon, Metro Manila, while respondents Gonzalo Go, Sr. owned Lots Nos. 25 and 26, on which his son Winston Go built a house in 1983, and Li Ching Yao owned Lot No. 27. In 1985 petitioner Ballatan constructed her home on Lot No. 24 only to discover that Winston Go’s concrete fence and side pathway encroached upon 42 sq. m. of her property. After two initial surveys by Engineer Jose N. Quedding—AIA’s authorized surveyor—which yielded conflicting area measurements, a third relocation survey on June 2, 1985 confirmed the encroachment and that Lots 25, 26 and 27 had shifted westward. Ballatan demanded the removal of respondent Go’s improvements; upon refusal, she filed Civil Case No. 772-MN for recovery of possession before the Regional Trial Court (RTC) of Malabon, Bra Case Digest (G.R. No. 125683) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Parties, properties, and construction timeline
- Petitioners Eden Ballatan and spouses Betty Martinez and Chong Chy Ling own Lot No. 24 (414 sqm) in Araneta University Village, Malabon.
- Respondent Gonzalo Go, Sr. owns Lots Nos. 25 (415 sqm) and 26 (313 sqm); his son Winston Go built on Lot No. 25.
- Respondent Li Ching Yao owns Lot No. 27 (417 sqm). Li built in 1982, Winston Go in 1983, and Ballatan in 1985.
- Discovery of encroachment and surveys
- During Ballatan’s 1985 construction, her contractor observed that Go’s fence and pathway encroached upon Lot 24’s eastern boundary.
- Engineer Jose N. Quedding (AIA surveyor) conducted:
- A 1983 verification survey – boundaries “proper.”
- A February 28, 1985 survey – Lot 24 short by a few meters; Lot 27 oversized by 2 m; no explanation for Lot 24’s loss.
- A June 2, 1985 relocation survey – Lot 24 lost ~25 sqm; Lot 26 lost 3 sqm (gained by Lot 27); Lots 25/26 net zero change; overall 42 sqm shift westward.
- Barangay proceedings and trial court decision
- Ballatan demanded removal of Go’s improvements on June 10, 1985; demand refused; barangay conciliation failed.
- April 1, 1986 – Ballatan filed Civil Case No. 772-MN (accion publiciana) before RTC Malabon, Branch 169. Go’s answer impleaded AIA, Quedding, and Li as third-party defendants.
- August 23, 1990 – RTC ruled for Ballatan:
- Order to demolish and remove improvements; vacate and deliver possession of encroached area.
- Payment to Ballatan: ₱7,800 (survey expenses), ₱5,000 (transportation), attorney’s fees (25% of market value at execution), costs.
- Dismissal of third-party complaint against AIA, Quedding, and Li.
- Court of Appeals decision (March 25, 1996)
- Affirmed dismissal as to AIA; reinstated third-party complaints against Quedding and Li.
- Modified relief: instead of demolition, ordered payment of reasonable value of encroached areas at time of taking—Go pays Ballatan for 42 sqm, Li pays Go for 37 sqm; Quedding to pay Go ₱5,000 attorney’s fees; remand to fix values.
Issues:
- Application of equity and valuation date
- Whether the CA erred by applying “equitable solutions” disregarding petitioners’ Torrens rights.
- Whether the CA should have fixed value at time of payment instead of time of taking.
- Jurisdiction over third-party complaint
- Whether failure to pay docket and filing fees deprived trial court and CA of jurisdiction over Go’s third-party complaint.
- Recovery of necessary expenses
- Whether petitioners were wrongly denied recovery of necessary expenses for protecting their rights.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)