Title
General Milling Corp. vs Constantino
Case
G.R. No. 195919
Decision Date
Nov 21, 2018
GMC, claiming land ownership, demolished 200 houses in Cagayan de Oro. Occupants sued, alleging ancestral rights. SC upheld GMC’s ownership, ruled demolition legal, denied damages.
ownership
disputed lands
respondents
A

Case Digest (G.R. No. 193374)

Facts:

  • Background and Ownership Claim
    • General Milling Corporation (GMC) claimed ownership over Lot Nos. 19053 and 21827, covering approximately 14,889 square meters in Umalag, Barangay Tablon, Cagayan de Oro City.
    • On January 7, 1991, GMC notified the Fiscal's Office and the City Building Official of its ownership while alleging that the occupants were squatters.
    • In response, Engineer Flavia Merilles, in a letter dated April 11, 1991, informed GMC’s counsel that the houses and structures on the property were illegally constructed without building permits under Section 301 of P.D. 1906, thus deeming the construction illegal and subject to demolition.
  • Initiation of the Controversy and Early Litigation
    • Respondents, residents of the subject lands, filed a Complaint for Cancellation of Miscellaneous Lease Application, Foreshore Lease Application, and TCT No. T-15846 with Injunction and Damages, seeking a Temporary Restraining Order (TRO) against GMC and Engr. Merilles on April 19, 1991.
    • The RTC initially denied the TRO on April 25, 1991, which enabled GMC to proceed with the demolition of approximately 200 houses on the subject lands.
    • An ocular inspection by the RTC on May 23, 1991, confirmed that 34 houses remained standing after the demolition.
  • Developments in the Trial Court
    • On July 28, 1993, the respondents amended their complaint, alleging:
      • They and their predecessors-in-interest had occupied the lands since time immemorial.
      • Their occupancy and constructed houses were continuously and openly maintained until GMC’s forcible eviction and demolition.
      • GMC challenged their claim by asserting its title—Lot No. 19053 had been registered in 1973, while Lot No. 21827 was allegedly in the name of its predecessor.
    • The trial court’s proceedings were delayed due to several postponements.
    • On February 11, 1997, despite ongoing litigation and continued attempts by GMC to access and build on the subject lands, the RTC issued a Writ of Preliminary Injunction restraining GMC from hindering the respondents’ access.
    • During trial, respondents presented witnesses Primitivo Lucido and Cristina Bajao, while GMC called its engineer Bienvenido Bacus.
    • On October 27, 1998, respondents moved that GMC be declared in contempt of court for allegedly violating the injunction, a motion which the RTC denied.
    • Ultimately, on July 1, 1999, the RTC rendered a Decision dismissing the case for lack of merit, ruling that GMC had sufficiently established its ownership and that the demolition was justified under Article 429 of the Civil Code. The RTC also ordered respondents to pay GMC P40,000.00 in attorney’s fees and litigation expenses.
  • Developments in the Court of Appeals
    • Respondents appealed the RTC Decision, and on October 28, 2009, the Court of Appeals (CA) reversed the trial court ruling.
    • The CA’s decision:
      • Awarded respondents nominal damages of P100,000.00, moral damages of P300,000.00, and exemplary damages of P300,000.00.
      • Ordered GMC to pay additional costs amounting to P20,000.00 for attorney’s fees and P5,000.00 for litigation expenses.
      • Found that GMC lacked authority over one of the lots (Lot No. 21827), citing issues with the tax declarations issued in 1991, and held that the right of petitioners as prior possessors superseded GMC.
    • The CA clarified that the City Building Official did not have the mandate to order demolition of structures solely based on the absence of building permits unless the structures were deemed dangerous under Sections 214 and 215 of the National Building Code.
  • Issues Raised in the Petition for Review on Certiorari
    • GMC contended that:
      • The CA erred in awarding damages to respondents who, it claimed, did not actually participate or appear before the trial court.
      • The verification of the complaint was questionable, particularly regarding the authority and existence of the Amihan Mindanao Farmers and Neighborhood Association.
      • Several of the 68 respondents listed were not residents of Tablon or could not have occupied the subject lands since time immemorial.
      • The testimonies of the two respondents’ witnesses were insufficient to substantiate the full range of damages awarded.
      • The allegation that 200 houses were demolished was inconsistent with the number of respondents actually filing the claim.

Issues:

  • Sufficiency of Evidence on Possession and Ownership
    • Whether the respondents adequately established by evidence their possession and ownership (or right of occupancy) over the subject lands.
    • Whether the lack of documentary evidence, such as tax declarations or receipts, undermined their claim.
  • Legality of the Demolition
    • Whether GMC’s demolition of the houses was legally justified under the letter from Engr. Merilles and Article 429 of the Civil Code.
    • Whether the City Building Official exceeded his authority by ordering demolition when the structures were not dangerous as required under the National Building Code.
  • Appropriateness of the Awarded Damages
    • Whether the award of nominal, moral, and exemplary damages by the CA was supported by sufficient evidence.
    • Whether respondents fully demonstrated that they suffered damages from the demolition, particularly given the existence of 34 houses that remained standing.
    • Whether the procedural and substantive requirements for awarding attorney’s fees were met under the applicable provisions.
  • Jurisdiction over Public Lands
    • Whether GMC’s claim over Lot No. 19053, a public land allegedly fraudulently titled, could be properly adjudicated within the scope of this case.
    • Whether the appropriate remedy for land title issues was reversion proceedings or annulment of prior judgments.

Ruling:

  • (Subscriber-Only)

Ratio:

  • (Subscriber-Only)

Doctrine:

  • (Subscriber-Only)
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