Case Digest (G.R. No. 195814) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In Eversley Childs Sanitarium, represented by Dr. Gerardo M. Aquino, Jr. (now Dr. Primo Joel S. Alvez), Chief of Sanitarium, Petitioner, v. Spouses Anastacio and Perla Barbarona, Respondents (G.R. No. 195814, April 4, 2018), the Sanitarium, a public health facility under the Department of Health, has occupied a portion of Lot No. 1936 in Jagobiao, Mandaue City, Cebu since May 30, 1930. Respondents claim ownership under Transfer Certificate of Title No. 53698, reconstituted from Decree No. 699021 issued in 1939 to their predecessors and subsequently conveyed to them in 2004. On May 6, 2005, the Spouses Barbarona filed an unlawful detainer complaint in the Municipal Trial Court in Cities (MTCC), alleging that the occupants were tolerated only temporarily and had refused a demand to vacate. The MTCC, and upon appeal the Regional Trial Court (RTC), ordered the Sanitarium to vacate, holding that an ejectment action lay and that respondents’ Torrens title conferred a prima facie right Case Digest (G.R. No. 195814) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Background and Parties
- Eversley Childs Sanitarium (ECS)
- A public health facility for Hansen’s disease patients, built 1928–1930 by Leonard Wood Memorial and donated by Eversley Childs.
- Opened May 30, 1930 on a portion of Lot No. 1936 in Jagobiao, Mandaue City; land reserved for the sanitarium by Proclamation No. 507 (Oct. 21, 1932).
- Spouses Anastacio and Perla Barbarona
- Claim ownership of Lot No. 1936 via Transfer Certificate of Title (TCT) No. 53698 (Feb. 7, 2005), derived from Decree No. 699021 issued March 29, 1939 to Spouses Tarcelo B. Gonzales and Cirila Alba.
- Allege they acquired the property by deed of renunciation and conveyance executed March 24, 2004 by the Gonzales heirs.
- Procedural History
- Trial and First Appeal
- May 6, 2005 – Barbaronas file ejectment complaint for unlawful detainer in MTCC – Mandaue City; allege ECS occupies by mere tolerance.
- Sept. 29, 2005 – MTCC orders ECS and other occupants to vacate, awards damages and attorney’s fees.
- Nov. 24, 2006 – RTC – Mandaue City affirms; ECS files MR.
- Feb. 19, 2007 – CA (G.R. CEB-SP No. 01503) annuls OCT RO-824 and derivative titles (including TCT 53698) for lack of notice to occupants.
- April 23, 2007 – RTC denies ECS’s MR.
- Second Appeal and Supreme Court Proceedings
- Petition for review filed by ECS in CA – SP No. 02762; Feb. 17, 2011 – CA affirms RTC and MTCC, rules action was unlawful detainer and title issues immaterial; denies ECS’s petition.
- May 13, 2011 – SC issues TRO on execution; ECS files petition for certiorari in SC; procedural issues on forum shopping arise over ECS’s concurrent MR in CA and SC petition.
- Aug. 31, 2011 – CA resolves and denies ECS’s MR despite ECS’s motion to withdraw it; SC later deems that resolution a legal nullity under CA’s Internal Rules.
Issues:
- Does the nullification of TCT No. 53698 invalidate the Barbaronas’ right of possession over Lot No. 1936?
- Was the Barbaronas’ complaint one for unlawful detainer (ejectment) or for accion publiciana?
- Did ECS commit forum shopping by filing a motion for reconsideration in the CA after petitioning the SC?
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)