Case Digest (G.R. No. 190207)
Facts:
In October 1997, the Heirs of Tomas Dolleton, Heraclio Orcullo, Remedios San Pedro, the Heirs of Bernardo Millama, the Heirs of Agapito Villanueva, the Heirs of Hilarion Garcia, Serafina SP Argana, and the Heirs of Mariano Villanueva (collectively, petitioners) filed eight separate Complaints for Quieting of Title and/or Recovery of Ownership and Possession with Preliminary Injunction, Restraining Order, and Damages against Fil-Estate Management Inc., spouses Arturo E. Dy and Susan Dy, Megatop Realty Development, Inc., and the Register of Deeds of Las Piñas City before the Regional Trial Court (RTC), Branch 253, Las Piñas City. The complaints, later consolidated, covered distinct parcels of land in Magasawang Mangga and Barrio Pugad Lawin, Las Piñas, Rizal, which petitioners claimed to have possessed continuously, openly, and exclusively for over 90 years, paying real estate taxes and cultivating the land until they were forcibly evicted by armed men hired by respondents betweenCase Digest (G.R. No. 190207)
Facts:
- Parties and proceedings
- Petitioners, heirs of multiple landowners, filed in October 1997 eight consolidated Complaints for quieting of title and/or recovery of ownership and possession with preliminary injunction in RTC, Branch 253, Las Piñas City, against Fil-Estate Management Inc., spouses Arturo E. Dy and Susan Dy, Megatop Realty Development, Inc., Peaksun Enterprises and Export Corporation, Elena Jao, and the Register of Deeds of Las Piñas City.
- The RTC dismissed the Complaints by Resolutions dated 8 September 2000 and 30 June 2003; the Court of Appeals in CA-G.R. CV No. 80927 affirmed by Decision of 16 September 2005 and denied petitioners’ Motion for Reconsideration on 9 December 2005.
- Subject properties and claims
- The subject properties consist of eight parcels in Mag-asawang Mangga and Barrio Pugad Lawin, Las Piñas, Rizal, ranging from 2,105 sqm to 29,391 sqm, which petitioners and their predecessors purportedly possessed continuously, openly, and exclusively for over 90 years and on which they paid real estate taxes.
- Respondents hold Transfer Certificates of Title Nos. 9176–9182, derived from OCT No. 6122 in favor of Jose Velasquez; petitioners allege these TCTs do not cover the subject properties and are spurious.
- Procedural motions and lower-court dismissals
- Respondents moved to dismiss on grounds of prescription (Sec. 32, PD 1529; Arts. 1144, 1456, Civil Code), laches, lack of cause of action, and res judicata (citing Vda. de Cailles v. Mayuga, Orosa v. Migrino, and MTC Civil Case No. 3271).
- On 8 September 2000, the RTC granted the motion in Civil Case No. LP-97-0228, and on 30 June 2003, extended the dismissal to all consolidated cases; petitioners appealed to the CA, which affirmed.
Issues:
- Cause of action
- Whether petitioners alleged sufficient facts to establish a cause of action for recovery of ownership and possession (acción reivindicatoria) under Article 428, Civil Code.
- Whether the prayer for cancellation of respondents’ TCTs contradicts petitioners’ allegation that the subject properties are not covered by those titles.
- Prescription and laches
- Whether petitioners’ action is barred by the one-year period under Sec. 32, PD 1529, or the ten-year period under Arts. 1144 and 1456, Civil Code.
- Whether petitioners’ alleged failure to act for decades constitutes laches, forfeiting their equity.
- Res judicata
- Whether Vda. de Cailles and Orosa, and the MTC Decision in Civil Case No. 3271, bar petitioners’ claims under “bar by prior judgment” or “conclusiveness of judgment.”
- Whether there is identity of parties, subject matter, and causes of action between the prior decisions and the instant Complaints.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)