Case Digest (G.R. No. 192268)
Facts:
In Department of Education v. Casibang et al., the property in dispute is a 7,532-square-meter portion of Lot 115 under Original Certificate of Title No. O-627 registered to the late Juan Cepeda, father of respondents Delfina C. Casibang, Angelina C. Canapi, Erlinda C. Bajan, Lorna G. Gumabay, Dionisia C. Alonzo, Maria C. Bangayan, and Digna C. Binayug. In 1965, Mayor Justo Cesar Caronan secured Cepeda’s permission to erect and operate Solana North Central School on the western portion of the lot. After Cepeda’s death in 1983, his heirs tacitly tolerated continued school use until October 2000, when they reoccupied a segment of the land. School authorities pursued them through the barangay, demanding their removal. When respondents refused, DepEd filed a forcible entry complaint in June 2001 before the Municipal Circuit Trial Court of Solana-Enrile, which ruled for DepEd and ordered respondents out. The Regional Trial Court of Tuguegarao City affirmed on appeal. Thereafter, respCase Digest (G.R. No. 192268)
Facts:
- Antecedents and Property Details
- The subject is a 7,532 sq m portion of Lot 115, covered by OCT No. O-627, registered in the name of Juan Cepeda.
- In 1965, at the request of Mayor Caronan, Cepeda permitted the construction and operation of Solana North Central School on the western portion of his land.
- Cepeda died in 1983; his descendants (respondents) continued to tolerate the school’s possession and use of the property.
- Procedural History
- October–November 2000: Respondents re-entered and occupied part of the property; school officials demanded they vacate.
- June 21, 2001: DepEd filed a complaint for forcible entry and damages (MCTC Solana-Enrile); the MCTC and RTC ruled in favor of DepEd.
- March 16, 2004: Respondents filed an action for recovery of possession and/or sum of money, claiming deprivation of use and entitlement to rent or compensation.
- Trial: Respondents presented OCT, tax declarations, tax receipts (since 1965), technical description, and court certification; DepEd failed to present evidence.
- January 10, 2008 (RTC): Declared respondents owners; ordered reconveyance or, as impracticable, payment of just compensation based on value at time of taking.
- April 29, 2010 (CA): Affirmed the RTC decision.
- June 18, 2010: DepEd, via OSG, filed petition for review on certiorari before the Supreme Court.
Issues:
- Whether respondents’ right to recover possession of the subject property is barred by prescription.
- Whether that right is barred by laches given DepEd’s long-continued occupation.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)