Case Digest (G.R. No. 250159)
Facts:
The case involves petitioners Susana Barcelo, Catherine B. Flores, Clariza B. Biato, Chesca B. Macapagal, Carlo Barcelo, and Camille Barcelo, represented by their attorney-in-fact Susana Barcelo, against respondents Dominador Riparip, Romeo Riparip, Romeo Riparip, Jr., and Danilo Tamallana. The dispute centers around a parcel of land located in Barangay Conversion, Pantabangan, Nueva Ecija, originally owned by Adolfo Barcelo, the husband of petitioner Susana Barcelo, who passed away on October 5, 2004. Following Adolfo's death, the petitioners inherited the property, which they had cultivated for years. In 2006, they discovered that respondent Dominador Riparip had encroached upon approximately one hectare of their land, constructing a nipa house and fencing the area. Despite their requests for him to vacate, Dominador refused, claiming that Adolfo had given him the land without any documentation. The petitioners filed a complaint with the Barangay Agrarian Reform Committ...
Case Digest (G.R. No. 250159)
Facts:
Ownership and Possession of the Property
- Adolfo Barcelo, the husband of petitioner Susana Barcelo and father of the other petitioners, was the registered owner of a 36,435-square-meter parcel of land in Barangay Conversion, Pantabangan, Nueva Ecija, covered by Katibayan ng Orihinal na Titulo Blg. P-1805.
- Adolfo and his family had been in possession of the property, cultivating it by planting vegetables and mango trees.
- Upon Adolfo's death on October 5, 2004, petitioners succeeded to the property.
First Encroachment (2006)
- In 2006, petitioners discovered that respondent Dominador Riparip had clandestinely encroached on approximately one hectare of the property.
- Petitioners demanded that Dominador vacate the encroached area, but he refused and even constructed a nipa house and fenced the perimeter.
- Petitioners filed a complaint before the Barangay Agrarian Reform Committee (BARC), but no settlement was reached as Dominador claimed the land was given to him by Adolfo, without presenting any proof.
- Due to financial constraints, petitioners did not immediately file a court action and tolerated Dominador's possession.
Second Encroachment (2013)
- In June 2013, petitioners discovered that Dominador, along with Romeo Riparip, Romeo Riparip Jr., and Danilo Tamallana (collectively, respondents), had occupied the remaining area of the property through strategy and stealth.
- Petitioners demanded that respondents vacate, but they refused and even threatened harm.
- Mediation at the barangay level failed, prompting petitioners to file a complaint for ejectment before the Municipal Trial Court (MTC) of Pantabangan, Nueva Ecija.
Respondents' Defense
- Respondents claimed that their grandfather, Marcelino Riparip, had been in possession of the property since 1980, cultivating it and planting mango trees.
- They argued that the property was originally public land and that Adolfo obtained the title through fraud and misrepresentation in his application for a Free Patent from the DENR.
- Respondents also contended that petitioners' cause of action had prescribed since more than one year had passed since the initial demand to vacate in 2006.
Petitioners' Reply
- Petitioners clarified that their demand letter was issued on August 8, 2013, and the complaint was filed on February 28, 2014, within the one-year prescriptive period.
Issue:
- Whether the Court of Appeals (CA) erred in dismissing petitioners' complaint for ejectment on the ground that it was improperly filed as an unlawful detainer case instead of a forcible entry case.
- Whether petitioners' Torrens title over the property prevails over respondents' claim of possession.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Conclusion:
The Supreme Court ruled in favor of petitioners, reinstating the RTC's decision and ordering respondents to vacate the property. The Court emphasized that petitioners' Torrens title prevails, and the complaint was properly filed as a forcible entry case within the prescriptive period.