G.R. No. L-11284 - Blas vs. De la Cruz

Simeon Blas (plaintiff and appellant) initiated an action seeking an injunction to prevent the defendants from destroying certain buildings and improvements on a specified parcel of land.

The land in dispute was already the subject of a prior legal proceeding involving its registration under the Torrens system.

Prior to the commencement of the present action, Vicente de la Cruz (defendant and appellee) had commenced an action in the Court of Land Registration for the registration of several parcels of land described in the petition.

Simeon Blas opposed the registration by presenting his opposition on June 14, 1912, claiming that a portion of the land was rightfully his.

A hearing was conducted where the portion of the land claimed by Blas was excluded from the parcels to be registered in favor of de la Cruz.

The decision from the Court of Land Registration was appealed by de la Cruz to the Supreme Court.

The Supreme Court modified the earlier decision (March 16, 1915) and ordered that the disputed portion be registered in the name of Vicente de la Cruz.

A final judgment was rendered, and the case was remanded to the lower court on April 19, 1915.

Following the registration proceedings, the plaintiff’s petition for an injunction was met with a demurrer by the defendants.

The lower court judge (Honorable Jose C. Abreu) sustained the demurrer, dissolved the temporary injunction, and allowed the plaintiff an opportunity to amend his petition.

Instead of amending, the plaintiff excepted to the order and appealed the decision.

The case fundamentally questions whether the registration decree under the Torrens system automatically includes any buildings and improvements on the land if they have not been expressly excluded during the litigation.

The issue was compounded by the statutory provisions under Act No. 496 (sections 38 and 39 as amended by Act No. 2011) which delineate exceptions related to the registration decree.

The plaintiff attempted to later claim the improvements under the doctrine of Article 453 of the Civil Code, which protects the possessor of real estate who has made improvements during a good faith occupation.

Whether the decree ordering the registration of land under the Torrens system includes buildings and improvements thereon that were not expressly excluded during the registration proceedings.
Whether a party (the objector) who fails to claim or note his rights to improvements during the registration process may later, by separate action, assert ownership over such improvements.
Whether Article 453 of the Civil Code, which guarantees benefits to the possessor in good faith, can be invoked after the registration process if the claim to improvements was not raised during the proceedings.