Case Digest (G.R. No. 241507)
Facts:
Republic of the Philippines, represented by the Regional Director of the Department of Education [DepEd]-Region II v. Heirs of Eriberto Ontiveros and Spouses Gerardo and Daisy Ontiveros, G.R. No. 241507, December 07, 2022, Supreme Court Second Division, Leonen, SAJ., writing for the Court.
The dispute concerns possession of a 1,811-square meter parcel in Gaddang, Aparri, Cagayan where the Department of Education constructed classrooms in the 1970s that became Gaddang Elementary School. On June 19, 2008, the heirs of Eriberto Ontiveros and Spouses Gerardo and Daisy Ontiveros (collectively, respondents) filed an accion publiciana seeking recovery of possession, alleging the lot was covered by Transfer Certificate of Title No. T-56977 in the name of Eriberto and Gerardo Ontiveros and asserting that the DepEd had only been permitted to erect temporary structures which later became permanent. Respondents claimed they demanded rent and gave DepEd the option to purchase but were not compensated or evicted, hence their suit for possession and rentals.
DepEd, through its Regional Director, answered asserting prescription and estoppel by laches, claiming proof of long, open, adverse possession since the 1970s, and denying respondents' title contentions while asserting it had a deed of sale and immunity from suit. At trial, respondents offered various documentary and testimonial evidence (including tax declarations and receipts, a deed of extrajudicial settlement, a relocation survey report, and a demand letter), while DepEd relied largely on its long occupation and some admissions. The Municipal Circuit Trial Court (Branch 2) rendered a March 30, 2016 Decision in favor of DepEd, finding respondents failed to prove a better right to possess—citing, among other things, the absence of the original TCT and lack of proof of prior demand.
The Regional Trial Court (Branch 8) reversed in a November 16, 2016 Decision, holding respondents had proved ownership and a better right to possession, noting DepEd judicially admitted the existence of a TCT (the opinion refers to TCT No. T-56997), and that respondents’ documentary evidence and survey corroborated their claim; it ordered DepEd to vacate and surrender possession. The Court of Appeals affirmed the RTC in a February 15, 2018 Decision (CA-G.R. SP No. 150080) and denied DepEd’s motion for reconsideration in an August 8, 2018 Resolution. DepEd then filed a Petition for Review on Certiorari under Rule 45 before the Supreme Court challenging ...(Subscriber-Only)
Issues:
- Did the Court of Appeals err in ruling that respondents proved their better right to possess the land?
- Did the Court of Appeals err in finding the Complaint for recovery of possession not barred by prescription and laches?
- Is the Department of Education a builder in good faith entitled to invoke Article 448, in relation to Arti...(Subscriber-Only)
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)