Title
J. M. Tuason and Co., Inc. vs. Jurilla
Case
G.R. No. L-19998
Decision Date
Apr 22, 1977
Plaintiff, registered landowner, sued defendants for possession; defendants claimed ownership via unregistered deed. Court upheld plaintiff's title, ruled defendants not in good faith, denied third-party inclusion, and affirmed eviction with rent payment.

Case Digest (G.R. No. L-19998)
Expanded Legal Reasoning Model

Facts:

  • Background of the Case
    • The dispute centers on a parcel of land covered by Transfer Certificate of Title No. 37186 (later reissued as No. 1267) in the name of plaintiff-appellee J. M. Tuason & Co., Inc.
    • Defendants-appellants, the spouses Vicente Jurilla and Ester L. Jurilla, asserted that they acquired certain possessory rights over a portion of the property through a deed of sale executed by a third-party, Florencio Deudor, in 1949.
    • The trial court, in an accion publiciana, ordered the defendants to vacate the land and to pay the plaintiff the sum of P100.00 per month from the filing of the action until possession was restored, alongside the payment of costs.
  • Procedural Background and Pre-Trial Proceedings
    • On August 14, 1962, counsel for the appellants filed a petition seeking the case’s transmission to the Court of Appeals so as to raise questions of fact.
    • The plaintiff opposed this, noting that the trial record had been approved with additional manifestations by the defendants regarding an intent to appeal on questions of law only.
    • Consequently, the trial court, on September 5, 1962, denied the petition, and the appeal was subsequently confined exclusively to issues of law.
  • Issues Surrounding the Claims and Evidence
    • Appellants raised eight distinct assignments of error, which included:
      • The denial of their motion to file a third-party complaint against Florencio Deudor.
      • The trial court’s determination that the appellants, as possessors and builders of the land, did not act in good faith and were therefore not entitled to indemnity for the improvements they introduced.
      • The assertion that the trial court erred in not recognizing the appellants’ status as possessors in good faith.
      • The contention that the plaintiff’s alleged indefeasible title was not absolute, particularly absent the compromise agreement.
      • The claim that the deed of sale (Annex “I”) either transferred title or constituted a lien favorable to the appellants.
      • The argument that the plaintiff should have been compelled to accept the appellants’ tender of payment in full.
      • The demand for an order directing the plaintiff to execute the final deed of sale upon full payment.
      • The protest against the trial court’s order mandating the vacation of the premises and the payment of P100.00 per month.
    • Evidentiary documents introduced in the proceedings included:
      • The Transfer Certificate of Title, which is deemed indefeasible under the Torrens system.
      • The deed of sale executed by Florencio Deudor (Annex “I”) and the Compromise Agreement (Annex “II”) along with its judicial approval (Annex “III”).
      • Testimonies and exhibits regarding the possession, structural improvements, and tender of payment (e.g., actions in 1949 and 1950).
  • Factual Findings from the Trial
    • It was established that the plaintiff’s title, evidenced by the duly registered and uncontradicted transfer certificate, was indefeasible and approved by the Office of the Register of Deeds.
    • The defendants had, without the knowledge or consent of the plaintiff, taken possession of a portion of the land and constructed improvements, although their claim of being buyers in good faith was undermined by their failure to inquire into the title of Florencio Deudor and the subsequent non-registration of the deed of sale.
    • The Compromise Agreement, according to its provisions, involved the plaintiff stepping into the shoes of Florencio Deudor with respect to certain rights and obligations, yet it did not recognize or convey any superior title to the appellants over the land.

Issues:

  • Whether the trial court erred in denying the appellants’ motion to file a third-party complaint against Florencio Deudor.
  • Whether the trial court properly determined that the appellants were not possessors or builders in good faith, and thus not entitled to indemnity for the improvements made on the land.
  • Whether the plaintiff’s title under the Torrens system, embodied in the Transfer Certificate of Title, is truly indefeasible, notwithstanding the appellants’ reliance on the deed of sale and the Compromise Agreement.
  • Whether the deed of sale (Annex “I”) or the Compromise Agreement (Annex “II”) amounts to a transfer of title, a lien, or an assumption of rights by the plaintiff in favor of the defendants.
  • Whether the plaintiff’s refusal to accept the appellants’ tender of full payment and to execute the final deed of sale was lawful given the terms of the Compromise Agreement.
  • Whether the trial court was correct in its order directing the appellants to vacate the premises and to pay P100.00 per month pending restoration of possession.

Ruling:

  • (Subscriber-Only)

Ratio:

  • (Subscriber-Only)

Doctrine:

  • (Subscriber-Only)

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