G.R. No. 146513 - Miranda vs. Besa

The subject property is located in Capas, Tarlac, originally comprising two lots – Lot 11 of plan Psu-127058-Amd (5,081 square meters) and Lot 18 of plan Psu-127058-Amd-2 (72,114 square meters).
On March 31, 1953, Macaria Capuno executed a deed of absolute sale in favor of the Spouses Alejandro Miranda and Feliza Garcia for a 254.03‑square-meter portion of the property, with specific boundaries (including premises such as Capas Elementary School and Real Street).
The Spouses Miranda later had the property surveyed (July 14, 1957), resulting in a technical description mapping out its boundaries and measurements, identifying the parcel by plan Psu-162708.

In 1960, Macaria Capuno, with counsel Atty. Tomas Besa, applied before the Court of First Instance (CFI) of Tarlac for the registration of the two lots. The application proceeded without opposition from the Spouses Miranda.
On November 26, 1960, the CFI rendered judgment granting the registration, and on February 17, 1961, Original Certificate of Title (OCT) No. O-1278 was issued based on the decision.
On March 6, 1967, Capuno executed a deed of absolute sale over Lot 18 in favor of Atty. Tomas Besa. The property was then subdivided into several lots (18-A, 18-B, 18-C, 18-D, 18-E, and 18-F), with further subdivision of Lot 18-F yielding additional titles later issued in the name of Tomas Besa.

In October 1968, Macaria Capuno filed a complaint with the CFI against Spouses Tomas and Esperanza Besa seeking the annulment of the deed of sale executed in her favor; the complaint was dismissed by the CFI and subsequently affirmed by the Intermediate Appellate Court (IAC) in 1986.
In the ensuing years, portions of the property changed hands, with titles being issued and even cancelled (e.g., TCT Nos. 209129, 292231, 292299, and 292806), leading to a reconfigured chain of title ultimately recorded in the name of Esperanza B. Besa.
The respondent, after having the property subdivided (May 6, 1997), discovered that petitioner Lucia Miranda occupied a portion of one of the sublots (Lot 18‑F‑3‑B‑2‑B‑1, 253 square meters).

On September 3, 1997, respondent Esperanza B. Besa filed a complaint for unlawful detainer against petitioner Lucia Miranda in the Municipal Circuit Trial Court, alleging that petitioner was unlawfully occupying her property despite prior notices.
In her answer to the complaint, petitioner relied on the deed of sale from Macaria Capuno to her deceased parents (the Spouses Miranda), asserting longstanding adverse and actual possession since birth.
After trial, the lower court rendered a judgment in favor of the respondent ordering petitioner and her agents to vacate the premises, with accompanying monetary awards for legal fees and detention.
On appeal, the RTC and subsequently the Court of Appeals (CA) affirmed the lower court’s decision, though with modifications (notably, the deletion of the award for attorney’s fees), while leaving open the issue of the title’s ownership for proper adjudication in future proceedings.

Petitioner advanced multiple contentions in her petition for review, including that:

The CA erred in not dismissing the respondent’s complaint for lack of jurisdiction or cause of action.
Respondent was deprived of any right to eject petitioner due to the uncontested sale of the property to petitioner’s parents.
The longstanding, bona fide occupation by petitioner and her family (over fifty years) should bar ejectment.
The lower court’s finding of estoppel and laches against petitioner, invoking res judicata, precluded any ownership claim by her.
The complaint was defective for failing to implead necessary parties (i.e., petitioner's husband and siblings).

Petitioner also contended that her family acquired a better title blemished by fraudulent conveyance to the respondent’s predecessor-in-interest, and that her adverse and uninterrupted possession entitles her to ownership by prescription.

Whether the lower courts had jurisdiction over the respondent’s ejectment complaint when petitioner interposed the defense of ownership.
Whether the ejectment complaint should have been dismissed for lack of jurisdiction or cause of action.

Whether respondent, as the registered owner by title, had the unequivocal right to eject petitioner despite the uncontroverted sale to petitioner’s parents.
Whether the defense of adverse possession (based on forty‐plus years of occupation) could effectively bar respondent’s ejectment action.

Whether the petitioner's assertions that the title was fraudulently obtained are subject to collateral attack or should be raised in a direct action.
Whether the appeal on the ground of acquisitive prescription is proper in an ejectment proceeding.

Whether the complaint was defective for failure to implead additional necessary parties (petitioner's husband and siblings) who also occupy portions of the disputed property.
Whether such nonjoinder is fatal to the respondent’s claim for ejectment.