Title
Lerias vs. Court of Appeals
Case
G.R. No. 193548
Decision Date
Apr 8, 2019
Spouses Yñiguez claimed ownership of land, contested by Southern Leyte. A compromise recognized their title, but CA issued an injunction favoring Southern Leyte. SC ruled CA abused discretion, upholding Yñiguez's Torrens title as indefeasible.
certiorari
writ of preliminary injunction
clear legal right
A

Case Digest (G.R. No. 90270)

Facts:

  • Parties and basic dispute over the subject property
    • Spouses Nicanor E. Yniguez and Salvacion Oppus-Yniguez (Spouses Yniguez) brought a complaint for quieting of title to a parcel of commercial land located at Barangay Abgao, Maasin, Southern Leyte.
    • The complaint was filed against Provincial Government of Southern Leyte (Southern Leyte) and Philson Construction and Development Corporation (Philson Construction).
    • The complaint was docketed as Civil Case No. R-2896 in the Regional Trial Court (RTC) in Maasin, Southern Leyte.
    • The Spouses Yniguez alleged they were the absolute owners of the property covered by Transfer Certificate of Title (TCT) No. T-1089.
    • The Spouses Yniguez averred they had paid real property taxes assessed on the property.
    • The Spouses Yniguez stated that Southern Leyte had annotated an adverse claim on April 30, 1991 under Entry No. 5479, following Sangguniang Panlalawigan Resolution No. 346-S. ’88.
    • The Spouses Yniguez alleged that Philson Construction started to build a multi-purpose center on the property without their consent and without having been issued the proper licenses from the concerned local government offices.
    • The Spouses Yniguez claimed that the acts of Southern Leyte and Philson Construction resulted in a cloud of doubt on their ownership.
    • The Spouses Yniguez prayed that they be declared lawful owners and that Southern Leyte and Philson Construction be enjoined from performing acts inimical to their rights.
    • The Spouses Yniguez sought, in addition, a restraining order and writ of preliminary injunction.
  • Southern Leyte’s defense regarding ownership and possession
    • Southern Leyte denied the alleged ownership of the Spouses Yniguez.
    • Southern Leyte traced the land covered by TCT No. T-1089 to TCT No. 150 and Original Certificate of Title (OCT) No. 35.
    • Southern Leyte insisted that the lot was sold to the Province of Leyte by Felix Aya-ay as guardian of then minors Josefina and Asuncion Oppus y Garces.
    • Southern Leyte asserted the sale was evidenced by a seller’s affidavit and a buyer’s affidavit, both dated June 3, 1918.
    • Southern Leyte asserted that the Province of Leyte paid real property taxes starting 1918.
    • Southern Leyte averred that upon its creation as a separate province, it was given the lot.
    • Southern Leyte claimed it had owned the contested property since 1918 and had been in continued peaceful possession.
    • Southern Leyte asserted that the Spouses Yniguez’ ownership was based on a deed of donation executed by Asuncion Oppus on May 28, 1986 of the lot purportedly covered by OCT No. 35 and TCT No. 150.
    • Southern Leyte stated that the lot donated was different from Southern Leyte’s lot.
    • Southern Leyte alleged that through fraud and misrepresentation, the Spouses Yniguez secured TCT No. T-1089 that eventually covered Southern Leyte’s lot.
  • Compromise agreement and RTC judgment approving it
    • The parties eventually entered into a compromise agreement as the basis of the RTC decision.
    • The compromise reflected resolutions of the Sangguniang Panlalawigan of Southern Leyte and authorization for the provincial officials to appeal for waiver and/or donation to the Province of Southern Leyte.
    • The compromise stated that Southern Leyte recognized the Spouses Yniguez’ ownership relative to the property in litigation covered by TCT No. 1089.
    • The compromise required the Sangguniang Panlalawigan to withdraw the offensive Resolution No. 338, series of 1991.
    • The compromise provided that the provincial government would accept the Spouses Yniguez’ proposal for the donation of land and a building erected as a usufruct for the Provincial Library.
    • The compromise authorized the Provincial Attorney (Atty. Teopisto C. Rojas, Jr.) to sign the compromise agreement in behalf of the province as provided in the Local Government Code.
    • The compromise imposed conditions:
      • The Spouses Yniguez would donate only the land and the building over which the Provincial Library was erected as a usufruct.
      • The donation would be contingent on the continued use of the building and land as a Provincial Library or museum.
      • If the Provincial Government ceased using the property for those functions, ownership and structures would automatically revert to the Spouses Yniguez and/or their heirs and successors-in-interest, who could immediately take possession without recourse by the Provincial Government of Southern Leyte.
      • The Provincial Government would be responsible for subdivision of the property subject to concurrence of the Spouses Yniguez or their duly assigned representatives, and related fees would be for its account.
    • On April 13, 2004, the RTC rendered judgment approving the compromise agreement.
    • The RTC judgment embodied the terms and conditions of the compromise agreement and enjoined the parties to comply strictly and faithfully.
  • Subsequent events: annulment action and donation to petitioner
    • Southern Leyte later claimed the compromise agreement had been entered into without authority of the Provincial Governor.
    • Southern Leyte initiated an action for annulment of the judgment in the Court of Appeals (CA), docketed as C.A.-G.R. CEB S.P. No. 03398.
    • While the annulment action remained pending, the Spouses Yniguez donated the disputed property to petitioner and Alfredo O. Yniguez by virtue of a deed of donation.
    • As a result, TCT No. 1089 was cancelled.
    • The Register of Deeds of Southern Leyte issued...(Subscriber-Only)

Issues:

  • Main issue on the propriety of the CA-issued preliminary injunction
    • Whether the CA-issued writ of preliminary injunction was issued with grave abuse of discretion amounting to lack or excess of jurisdiction.
  • Sub-issues raised by petitioner on clear legal right and irreparable injury
    • Whether Southern Leyte failed to show a clear and unmistakable right to be protected.
    • Whether Southern Leyte’s claim of ownership relied merely on tax declaration made in 1918, compared to petitioner’s Torrens title.
    • Whether there was no evidence showing Southern Leyte’s actual possession.
    • Whether petitioner...(Subscriber-Only)

Ruling:

  • (Subscriber-Only)

Ratio:

  • (Subscriber-Only)
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