Case Digest (G.R. No. 222614) Core Legal Reasoning Model
Facts:
This case involves the petition filed by Remedios Cardenas-Tumlos, represented by her attorney-in-fact Janet Tumlos-Quizon, as the heir of the late spouses Pastora T. Cardenas and Eustaquio Cardenas (collectively, the Sps. Cardenas), against The Christian and Missionary Alliance Churches of the Philippines, Inc. (CAMACOP), represented by Reo Repollo and Leocadio Duque, Jr. The dispute arose over Lot 90, Psd-37322, a real property of 410 square meters located in Poblacion 6, Midsayap, Cotabato, covered by TCT No. T-6097 and Tax Declaration No. K-019938, which is registered under Sps. Cardenas. CAMACOP's adjacent property is Lot 3924-A, Psd-12-013791, where their church is located.
On October 26, 2009, a Complaint for Recovery of Possession and Use of Real Property and Damages was filed before the Regional Trial Court (RTC) of Midsayap, Cotabato, Branch 24. The Heir of Sps. Cardenas asserted that CAMACOP unlawfully occupied the subject property since 1962 without any valid ti
Case Digest (G.R. No. 222614) Expanded Legal Reasoning Model
Facts:
- Parties and Subject Matter
- Petitioner is Remedios Cardenas-Tumlos (Remedios), heir of the late spouses Pastora T. Cardenas and Eustaquio Cardenas (collectively Sps. Cardenas), represented by her attorney-in-fact Janet Tumlos-Quizon (Janet).
- Respondent is The Christian and Missionary Alliance Churches of the Philippines, Inc. (CAMACOP), represented by Reo Repollo and Leocadio Duque, Jr.
- The dispute involves Lot 90, Psd-37322, a 410-square meter property located in Poblacion 6, Midsayap, Cotabato, covered by Transfer Certificate of Title (TCT) No. T-6097 and Tax Declaration No. K-019938 (the subject property).
- CAMACOP’s church premises are adjacent to the subject property on Lot 3924-A, Psd-12-013791.
- Complaint and Allegations
- On October 26, 2009, Remedios, through Janet, filed a Complaint for Recovery of Possession and Use of Real Property and Damages before the RTC of Midsayap, alleging that CAMACOP unlawfully occupied the entire 410-square meter subject property since 1962.
- Remedios asserted ownership of the property as heir of the registered owners, the late Sps. Cardenas, whose title and tax declarations remained under their names.
- Repeated demands to vacate the property by CAMACOP were allegedly ignored by the respondent.
- Respondents’ Defense
- CAMACOP admitted that Sps. Cardenas were the registered owners but claimed lawful sale of the subject property by Pastora Cardenas to CAMACOP pursuant to a 1962 Deed of Sale.
- It was alleged that all copies of the Deed of Sale were submitted to the Secretary of Agriculture and Natural Resources for prior approval as required by Commonwealth Act 141.
- CAMACOP argued the continuous occupation for 47 years extinguished the petitioner’s claim by prescription and laches.
- Lower Courts’ Proceedings and Decisions
- The RTC rendered a decision on June 6, 2012, dismissing the complaint for lack of merit, finding sufficient evidence of the 1962 sale from Pastora to CAMACOP.
- The petitioner filed a notice of appeal which the Court of Appeals (CA) denied in its February 16, 2015 Decision, affirming the RTC.
- Petitioner’s motion for reconsideration before the CA was denied on December 2, 2015.
- Present Petition before the Supreme Court
- The Heir of Sps. Cardenas filed a Petition for Review on Certiorari assailing the rulings of the CA, arguing error in the appreciation of evidence and upholding of the alleged 1962 sale.
Issues:
- Whether the Heir of Sps. Cardenas (Remedios) has a better right to possess the subject property than CAMACOP.
- Whether CAMACOP proved the validity of the purported 1962 Deed of Sale covering the entire 410-square meter subject property.
- Whether CAMACOP acquired possession of the property by prescription or that laches bars the Heir of Sps. Cardenas from recovering possession.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)