Facts:

The case revolves around an unlawful detainer action initially filed in the Municipal Court of Navotas, Rizal, with the plaintiffs being Sergio Santos and Juliana Ortiz, and the defendant being Fabian Borlas. The events unfolded when the plaintiffs claimed ownership of a parcel of land in Tangos, Navotas, Rizal, as established by their Transfer Certificate of Title No. 177436, covering an area of 555 square meters. The evidence presented by the plaintiffs indicated that a verbal contract was formed in June 1966, whereby Borlas was allowed to occupy the land for a monthly rental of P10.00. However, Borlas ceased paying rent in December 1966 and refused to vacate the premises despite multiple demands from the plaintiffs.

In contrast, Borlas provided evidence of his possession of a 259-square meter foreshore area in Navotas since 1955, which he claimed to have acquired from a previous owner, Concordia Pascual. He alleged peaceful possession of the land, having filed a sales applica

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Facts:

Parties and Origin of the Case

• Petitioner Fabian Borlas originally filed an unlawful detainer case in the Municipal Court of Navotas, Rizal.
• The case involved issues of possession over a parcel of land, with the plaintiffs—Sergio Santos and Juliana Ortiz—being the registered owners.
• The decision of the Municipal Court was in favor of the plaintiffs, which was later affirmed by the Court of Appeals.

Description of the Land and Title Issues

• The plaintiffs are the registered owners of a parcel of land located in Tangos, Navotas, Rizal.
• The land is described as having an area of 555 square meters, originally covered by Torrens Certificate of Title (TCT) No. 177436.
• Prior to this, the plaintiffs secured Optical Certificate of Title (OCT) No. 5279 on March 12, 1966, as evidence of their long-standing possession—having been in possession for at least thirty years before registration proceedings.
• Subsequently, OCT No. 5279 was cancelled with the issuance of new TCTs (Nos. 176788, 176789, and 177436), although the plaintiffs eventually retained only the parcel covered by TCT No. 177436.

The Lease Agreement and Possession Claims

• In June 1966, the defendant and the plaintiffs entered into a verbal month-to-month lease agreement at a rental of ₱10.00 per month.
• The defendant, Fabian Borlas, occupied a house allegedly purchased from one Concordia Pascual on the said land.
• Initially, the defendant paid the agreed rental until December 1966 but later ceased payment and refused to vacate the premises after being repeatedly demanded both orally and in writing.

Defendant’s Counter Claims and Evidence

• Borlas presented evidence that he had been in possession of a portion of a 259-square-meter foreshore area in Navotas, Rizal since 1955, having acquired it from Concordia Pascual.
• He asserted that his possession was peaceful, continuous, and adverse (against all except the government).
• On January 14, 1963, he filed a sales application with the Bureau of Lands to formalize his ownership based on his possession under a permit previously issued by the Bureau.
• Despite his claims, the land in dispute was conclusively covered by a Torrens Title held by the private respondents.

Evidentiary Basis for Prior Possession

• The Court of Appeals based its finding of prior possession by the plaintiffs on OCT No. 5279, despite subsequent administrative cancellations and the issuance of new TCTs.
• Restoration of OCT No. 5279 was granted by the Court of First Instance of Rizal on October 2, 1973, thereby reaffirming its evidentiary value.
• The identical description of the land in TCT No. 177436 and the restored OCT No. 5279 reinforced the plaintiffs’ claim to prior, uninterrupted possession.

Issue:

Identification and Integrity of the Land

• Whether the land in dispute was properly identified, particularly in light of the canceled OCT No. 5279 and the subsequent issuance of multiple TCTs.
• Whether the cancellation of OCT No. 5279 due to anomalies in the issuance of the new TCTs impacts its evidentiary value in establishing prior possession.

Prevailing Right of Possession

• Whether the prior possession evidenced by OCT No. 5279 (restored later by the Court of First Instance) is sufficient to establish the plaintiffs’ right to hold the land.
• Whether the defendant’s reliance on his possession under a Bureau of Lands permit and the subsequent sales application (which was denied) can outweigh the evidence of prior possession of the plaintiffs.

Attacking the Certificate of Title

• Whether the certificate of title (TCT No. 177436) can be subject to collateral attack in an unlawful detainer action when its validity is challenged by conflicting possession claims.
• Whether the separation of issues between possession and actual title ownership is maintained in cases where the certificate holds conclusive evidence of prior possession.

Ruling:

• (Subscriber-Only)

Ratio:

• (Subscriber-Only)

Doctrine:

• (Subscriber-Only)